Zambezia Film Pty, Ltd v. Does, No. 13 C 1323 & 1741, Slip Op. (N.D. Ill. Mar. 20, 2013) (Shadur, Sen. J.).

Judge Shadur sua sponte ordered plaintiff Zambezia Film to identify those Doe defendants that could be properly joined pursuant to Fed. R. Civ. P. 20(a)(2) in this BitTorrent “swarm” copyright case.  The Court would dismiss the remaining defendants.  Relying upon a Michigan Law Review student note — The Case Against Combating BitTorrent Piracy Through Mass John Doe Copyright Infringement Lawsuits, 111 Mich. L. Rev. 283 (2012) — the Court required that Zambezia Film identify those Does that were both part of the same swarm and part of the same swarm at the same time as one another.  Any other defendants would be dismissed.