Signature Management Team, LLC v. Doe, 876 F.3d 831

Background

Plaintiff Signature Management Team, LLC (Team) sued an anonymous blogger ("John Doe") after Doe posted a hyperlink to a downloadable copy of Team’s copyrighted book on his blog and removed it only after a DMCA takedown.
Team sought injunctive relief and disclosure of Doe’s identity; Doe asserted fair use, copyright-misuse, and a First Amendment right to anonymous speech.
At discovery the district court applied a pre-judgment balancing test (Art of Living style) and compelled disclosure to the court and counsel but kept Doe’s identity sealed from Team.
After discovery the district court denied Doe’s summary-judgment defenses, entered summary judgment for Team, ordered Doe to destroy copies of the Work, but refused to unmask Doe, reasoning no ongoing injunction was needed and Doe had complied.
Team appealed only the refusal to unmask Doe; the Sixth Circuit majority remanded, holding the district court failed to apply the strong presumption of openness applicable post-judgment and directed reconsideration under that presumption.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Doe’s identity must be disclosed post-judgment	Team: strong presumption of open judicial records requires unmasking an adjudicated infringer	Doe: First Amendment protects anonymous online speech; unmasking would chill protected speech	Remand to district court to apply a presumption favoring unmasking at judgment stage and balance public interest, plaintiff’s need, and Doe’s anonymous-speech interests
Effect of adjudication of copyright infringement on anonymity	Team: a finding of infringement removes anonymity protection for that conduct	Doe: his infringing act occurred amid protected anonymous speech and disclosure would chill other lawful speech	Court: infringement is unprotected, but anonymity may still implicate protected speech; thus infringement does not automatically end anonymity — balancing required
Standard to apply post-judgment vs. at discovery	Team: district court misapplied the pre-judgment discovery balancing test and ignored the stronger presumption of openness post-judgment	Doe: discovery-stage protections remain important to prevent chilling	Court: different, stronger considerations apply post-judgment; courts should presume unmasking unless balanced reasons weigh against it
Whether there is practical need to unmask where defendant complied with relief	Team: plaintiff needs identity to enforce and monitor compliance and give effect to judgment	Doe: having complied, no practical need and disclosure would be irreversible harm	Court: compliance reduces the plaintiff’s need and is a factor for anonymity; district court must weigh this against public interest on remand

Key Cases Cited

McIntyre v. Ohio Elections Comm’n, 514 U.S. 334 (1995) (anonymity is protected speech under the First Amendment)
Reno v. ACLU, 521 U.S. 844 (1997) (Internet speech receives full First Amendment protection)
Brown & Williamson Tobacco Corp. v. FTC, 710 F.2d 1165 (6th Cir. 1983) (strong presumption in favor of open judicial records)
Shane Group, Inc. v. Blue Cross Blue Shield of Michigan, 825 F.3d 299 (6th Cir. 2016) (only the most compelling reasons justify sealing court records; courts must explain specific reasons)
In re Knoxville News-Sentinel Co., Inc., 723 F.2d 470 (6th Cir. 1983) (compelling reasons required to overcome presumption of access)
In re Anonymous Online Speakers, 661 F.3d 1168 (9th Cir. 2011) (survey of balancing tests for unmasking anonymous online speakers)
Highfields Capital Mgmt., L.P. v. Doe, 385 F. Supp. 2d 969 (N.D. Cal. 2005) (balancing harms when deciding whether to disclose anonymous online defendants)
Arista Records, LLC v. Doe 3, 604 F.3d 110 (2d Cir. 2010) (copyright infringement is not protected by the First Amendment)