Development Dimensions International, Inc. v. Doe 1, 2:25-cv-00315

Background

Development Dimensions International, Inc. (DDI) sued 16 unidentified John Doe defendants for operating a fraudulent invoicing scheme using DDI's trademarks.
The scheme involved sending fake emails and invoices to DDI's customers, causing payments to be deposited in accounts held by now-dismissed banking defendants.
DDI originally obtained documents from the banking defendants which revealed an IP address linked to Comcast Corporation.
The IP address was used to open a fraudulent bank account in DDI’s name, allegedly facilitating the fraudulent activity.
DDI sought leave to serve a third-party subpoena on Comcast, before the Rule 26(f) conference, to discover the identity linked to the IP address.
The only remaining defendants are the unknown John Does; bank defendants were dismissed after providing identifying documents.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Can DDI seek expedited discovery before a Rule 26(f) conference to identify John Doe from ISP records?	DDI argues good cause exists: the info is essential to identify the defendant and advance the case; the request is narrow and time-sensitive.	No opposition recorded from John Doe; bank defendants dismissed.	Court grants DDI's motion, allowing subpoena to Comcast for subscriber info tied to the IP address.

Key Cases Cited

Arista Records, LLC v. Does 1–15, 2007 WL 5254326 (S.D. Ohio Nov. 5, 2007) (supports expedited discovery when plaintiff needs info to identify Doe defendants) Malibu Media, LLC v. Doe, 2015 WL 12732859 (S.D. Ohio Apr. 13, 2015) (provides factors for good cause in expedited discovery)

(Note: No key cases with official reporter citations were cited in this opinion, only district court decisions and WL citations.)