Pacific Century International, Ltd. v. Does 1-101, No. 4:11-cv-02533 (N.D. Cal. July 8, 2011), is a court case where Pacific Century International requested to subpoena the names and identities of 101 BitTorrent users (elsewhere noted as Does) whose IP Addresses were tied to downloading one of their copyrighted works. The resulting court decision permitted Pacific Century International to subpoena the identity of Doe 1, but dismissed claims against Does 2-101 for failure to demonstrate that the Does had operated as a single group while distributing the torrent, preventing each users' subpoena request from being enjoined into a single court filing. This case set a precedent for disallowing filings against large groups of IP addresses used to distribute copyrighted works over peer-to-peer networks. Background Pacific Century International controlled the copyright of Amateur Creampies -- Erin Stone ("the Work") and sought to reveal the identities of Does 1-101 who Pacific Century International contended had committed copyright infringement under by downloading and distributing Pacific Century International's work over BitTorrent. Pacific Century International discovered the defendants' IP addresses through its own investigations. In order to take legal action against the defendants, Pacific Century International sought to subpoena each defendant's ISP in order to obtain their "name, address, telephone number, e-mail address, and Media Access Control information". Due to the limited time ISPs keep such logs, Pacific Century International requested that expedited discovery be permitted. Court Findings Expedited Discovery In determining whether expedited discovery could be used to subpoena the identities of Does 1–101, the court considered Columbia Insurance Company, 185 F.R.D People who have committed no wrong should be able to participate online without fear that someone who wishes to harass or embarrass them can file a frivolous lawsuit and thereby gain the power of the court's order to discover their identity. Thus some limiting principals should apply to the determination of whether discovery to uncover the identity of a defendant is warranted. The following safeguards will ensure that this unusual procedure will only be employed in cases where the plaintiff has in good faith exhausted traditional avenues for identifying a civil defendant ... The court's justification for overcoming these safeguards and granting expedited discovery follows previous precedent set down by UMG Recordings, Inc. In this previous ruling, the courts determined a test for subpoenaing the identities of unnamed Does: (1) a sufficiently "concrete showing of a prima facie claim of actionable harm," including