Brown v. Does 1-20

CourtDistrict Court, W.D. Washington
DecidedMay 19, 2025
Docket3:25-cv-05256
StatusUnknown

This text of Brown v. Does 1-20 (Brown v. Does 1-20) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Brown v. Does 1-20, (W.D. Wash. 2025).

Opinion

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5 6 7 UNITED STATES DISTRICT COURT 8 WESTERN DISTRICT OF WASHINGTON AT TACOMA 9 10 PATRICK BROWN, CASE NO. 3:25-cv-05256-LK 11 Plaintiff, ORDER DENYING EX PARTE 12 v. MOTION FOR EARLY DISCOVERY 13 DOES 1-20, 14 Defendants. 15 16 Before the court is pro se Plaintiff Patrick Brown’s Ex Parte Motion for Early Discovery. 17 Dkt. No. 9. Having considered the motion, the relevant portions of the record, and the governing 18 law, the Court DENIES the motion. 19 I. BACKGROUND 20 Mr. Brown owns and operates a portfolio of “premium fetish adult-oriented audiovisual 21 content[.]” Dkt. No. 7 at 5. He alleges that he holds copyrights in these audiovisual works. Id. at 22 5–6. He has sued 20 defendants that are “currently unknown individual(s) and/or entity(ies) that 23 own and operate four websites” comprising a “Pirate Network” that allegedly display his 24 copyrighted works without license or authorization. Id. at 1–2. 1 II. DISCUSSION 2 Mr. Brown seeks to serve subpoenas on “the website hosting companies and internet 3 service providers associated with the . . . Pirate Network and the delivery of its content” in order 4 to “discover the true identity of” defendants and then “serve them with process in this case.” Dkt.

5 No. 9 at 2. Although Mr. Brown attests that he has contacted various of these companies and 6 providers, they have either not responded or indicated that they would not produce information 7 without a subpoena. Dkt. No. 11 at 1–2. 8 A. Jurisdiction and Venue 9 Mr. Brown raises a claim of copyright infringement under the Copyright Act, 17 U.S.C. § 10 101 et seq. Dkt. No. 7 at 11–13. “[J]ust because a case involves a copyright does not mean that 11 federal subject matter jurisdiction exists”; to properly invoke federal subject matter jurisdiction, 12 one of three things must exist: (1) the complaint asks for a remedy expressly granted by the 13 Copyright Act; (2) the complaint requires an interpretation of the Act; or (3) federal principles 14 should control the claims. Scholastic Ent., Inc. v. Fox Ent. Grp., Inc., 336 F.3d 982, 985–86 (9th

15 Cir. 2003). Here, Mr. Brown seeks remedies expressly granted by the Copyright Act—i.e., actual 16 damages, statutory damages, and injunctive relief. Dkt. No 7 at 12–13 (citing 17 U.S.C. §§ 502– 17 504). Accordingly, he has provided a basis for jurisdiction under 28 U.S.C. §§ 1331 and 1338(a). 18 However, as explained below, it is unclear whether Mr. Brown has standing, and Mr. 19 Brown has also not demonstrated a good-faith belief that this Court has personal jurisdiction over 20 defendants or that venue is proper in this District. 21 B. Legal Standard 22 Federal Rule of Civil Procedure 26 provides that “a party may not seek discovery from any 23 source before the parties have conferred as required by Rule 26(f)” unless authorized by the Court.

24 Fed. R. Civ. P. 26(d)(1). However, the Ninth Circuit has held that when a defendant’s identity is 1 unknown at the time the complaint is filed, a court should grant leave to take early discovery to 2 determine that defendants’ identities “unless it is clear that discovery would not uncover the 3 identities, or that the complaint would be dismissed on other grounds.” Gillespie v. Civiletti, 629 4 F.2d 637, 642 (9th Cir. 1980). A party who requests early or expedited discovery must make a

5 showing of good cause. See Semitool, Inc. v. Tokyo Electron Am., Inc., 208 F.R.D. 273, 275–76 6 (N.D. Cal. 2002) (applying “the conventional standard of good cause in evaluating Plaintiff’s 7 request for expedited discovery”). 8 To determine whether “good cause” exists to permit expedited discovery to identify Doe 9 defendants, district courts in the Ninth Circuit consider whether the plaintiff (1) “identif[ies] the 10 missing party with sufficient specificity such that the Court can determine that [the] defendant is 11 a real person or entity who could be sued in federal court”; (2) “identif[ies] all previous steps taken 12 to locate the elusive defendant” to ensure that plaintiff has made a good faith effort to identify the 13 defendant; (3) “establish[es] to the Court’s satisfaction that plaintiff’s suit against defendant could 14 withstand a motion to dismiss”; and (4) “justif[ies] the specific discovery requested as well as

15 identifi[es] a limited number of persons or entities on whom discovery process might be served 16 and for which there is a reasonable likelihood that the discovery process will lead to identifying 17 information about [the] defendant that would make service of process possible.” Columbia Ins. 18 Co. v. seescandy.com, 185 F.R.D. 573, 578–80 (N.D. Cal. 1999).1 A district court’s decision to 19 grant discovery to determine jurisdictional facts is a matter of discretion. See Wells Fargo & Co. 20 v. Wells Fargo Express Co., 556 F.2d 406, 430 n.24 (9th Cir. 1977). 21 1 This test reflects relevant considerations under Federal Rules of Civil Procedure 45 and 26. Rule 45(d)(3)(A) requires 22 a district court to “quash or modify a subpoena that . . . subjects a person to undue burden.” “If a subpoena compels disclosure of information that is not properly discoverable, then the burden it imposes, however slight, is necessarily 23 undue: why require a party to produce information the requesting party has no right to obtain?” AF Holdings, LLC v. Does 1-1058, 752 F.3d 990, 995 (D.C. Cir. 2014). In turn, Rule 26(b)(1) limits discovery to subject matter “that is relevant to any party’s claim or defense.” “The identity of prospective defendants who cannot properly be sued in this 24 district can be of little use in a lawsuit brought in this district.” AF Holdings, 752 F.3d at 995. 1 C. Mr. Brown has Failed to Show Good Cause for Early Discovery 2 Even assuming without deciding that Mr. Brown has satisfied the first, second, and fourth 3 ||components of the four-part test regarding expedited discovery, he has not shown that his suit 4 || could withstand a motion to dismiss. 5 1. Itis Unclear Whether Mr. Brown has Standing 6 First, the Court has been unable to verify that Mr. Brown owns the subject copyrights. For 7 example, Mr. Brown alleges that he owns copyrights with the following registration numbers: 8 PA0001706340 PA0001707340 9 PA0001707341 PA0001707342 0 PA0001707343 PA0001707344

12 || Dkt. No. 1-6 at 2. But a search of copyright registration numbers beginning with “PA000170734” 13 || on copyright.gov yields the following result: 14 Advanced Search Select record type to begin advanced search 15 © Allrecords [ Registration [ Recordation Field Heading Search Type 1 6 All Copyright Numbers 7 Starts with ¥ PAQOOT70734 + Add arow 17 es 18 Search Results® Top search results: 9 1 9 Displaying: 1-9 of 9 O GridView Table View 20 Oo 1. Full Title: Watch my lips (read my eyes)_/by Harlan Howard, Kavin Welch. Registration Number: PAQOOO170734 Date: 1983-03-10 2 1 Type of Work: Music Claimant: Tree Publishing Company, Inc. & Cross Keys Publishing -.. 22 oO 2.

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Brown v. Does 1-20, Counsel Stack Legal Research, https://law.counselstack.com/opinion/brown-v-does-1-20-wawd-2025.