Therefore, once the plaintiff has stated a prima facie case of copyright infringement in the complaint, the court should allow for expedited discovery to uncover the true identities behind the IP
addresses. Importantly, however, under Rule 26(c)(1) of the Federal Rules of Civil Procedure, “[t]he court may, for good cause, issue an order to protect a party or person from annoyance, mbarrassment,
oppression, or undue burden or expense . . . .”169 Allowing Doe defendants to remain anonymous throughout the proceedings is proper even though the public has a “legitimate interest” in knowing
the identities of parties involved in litigation in the federal courts.170 Keeping the defendants’ identities anonymous for the initial stages of litigation will protect them from being harassed by overzealous
copyright trolls merely hoping to extract quick settlement dollars. Although there is a “presumption of openness in judicial proceedings,”171 the court, in its discretion, can grant the “rare dispensation” of anonymity, so long as the court inquires into the circumstance of the particular case before doing so.172