TCYK, LLC v. Does 1-28, No. 13 C 3839, Slip Op. (N.D. Ill. June 24, 2013) (Guzman, J.).

Judge Guzman sua sponte severed Does 2-28 and dismissed them without prejudice in this Bit Torrent copyright case.  Joinder was not proper pursuant to Fed. R. Civ. P. 20 because while the Does were allegedly part of the same “swarm,” they were not part of it at the same time.  Furthermore, the Court exercised its Fed. R. Civ. P. 21 discretion to sever and dismiss all but one Doe, noting that multi-Doe Bit Torrent cases were a “logistical nightmare.”

The Court also denied early discovery as to the remaining Does’ identity because plaintiff TCYK had not shown the necessary good cause for early discovery.