Strike 3 Holdings Defendant Name Public: When Judges Require the Name in the Amended Complaint

When is a Strike 3 Holdings defendant name public? In most Strike 3 Holdings cases, federal judges let the person sued as “John Doe” stay anonymous, at least through the early stages. Some judges see it differently. They have ruled that the defendant’s real name belongs in the public record once Strike 3 files an amended complaint, unless the defendant shows a strong reason to keep it private. This guide quotes the judges who made the Strike 3 Holdings defendant name public, in their own words, and links to each order.

When is a Strike 3 Holdings defendant name public?

Every Strike 3 Holdings case starts against a “John Doe subscriber assigned IP address.” The court then lets Strike 3 subpoena the internet provider for the account holder’s name and address. After the provider responds, Strike 3 may file an amended complaint that names a person. That is the point where the question comes up: does the new name go on the public docket, or does it stay sealed or redacted?

In many federal courts, the order that allows the subpoena also says the defendant may proceed as John Doe unless the court orders otherwise. Strike 3 itself often asks to file the unredacted amended complaint under seal. Federal Rule of Civil Procedure 10(a), however, says the title of a complaint must name all the parties. A few judges have relied on that rule and on the public’s right of access to court records, and they have made the Strike 3 Holdings defendant name public unless the defendant shows a strong reason for privacy.

Why some judges make the Strike 3 Holdings defendant name public

The judges below each explained their reasoning in writing. Each court is listed separately. No defendant is named here.

District of New Jersey (Camden): Chief Judge Renée Marie Bumb

In 1:21-cv-15638, Strike 3 and the defendant had settled. They jointly asked the court to enter a consent judgment, keep the defendant’s pseudonym in the caption, and keep identifying documents under seal. On October 26, 2022, Chief Judge Bumb (then a district judge) denied that request without prejudice and gave the defendant 30 days to offer more support (ECF No. 23, opinion). She found that worry about employment and reputation, without more, was not enough.

“Thus, it certainly cannot be the case that anonymity is warranted for every defendant sued by Plaintiff simply because Plaintiff’s copyrighted works are adult films, legal in all respects other than how the defendants in these cases obtained and/or shared them via the BitTorrent protocol. … More specifically, the Court finds that the public has a strong interest in understanding how Plaintiff is using the federal courts, including against whom.— Chief Judge Renée Marie Bumb (then U.S. District Judge), U.S. District Court for the District of New Jersey, Strike 3 Holdings, LLC v. John Doe, No. 1:21-cv-15638, ECF No. 23, Opinion at 12–14 (Oct. 26, 2022). Read the opinion (PDF)

The same opinion also said that only the court decides anonymity. A plaintiff’s agreement to it does not decide the question. Strike 3 cited this opinion in a 2026 Newark case, discussed below.

District of New Jersey (Newark): a 2025 letter opinion

On January 7, 2025, in 2:24-cv-09433, the court denied a Strike 3 defendant’s request for a protective order to proceed under a pseudonym (ECF No. 11, letter opinion and order). The defendant’s name had already appeared in an exhibit the defendant filed. The court weighed the Third Circuit’s anonymity factors, and the ruling left the Strike 3 Holdings defendant name public on the docket. The court wrote:

“But unless those hurdles will cause those defendants severe harm, the public’s inherent interest in obtaining the identity of the parties outweighs those defendants’ desire to proceed anonymously.— U.S. District Court for the District of New Jersey, Strike 3 Holdings, LLC v. John Doe Subscriber Assigned IP Address 173.54.29.135, No. 2:24-cv-09433, ECF No. 11, Letter Opinion and Order at 7 (Jan. 7, 2025). Read the order (PDF)

District of New Jersey (Newark): what happens in 2026 cases

In 2:26-cv-08887, Strike 3 asked Magistrate Judge Jessica S. Allen for permission to seek the subpoena. In its July 17, 2026 letter, which the judge signed as an order on July 20, 2026 (ECF No. 6), Strike 3 wrote that, “due to recent decisions concerning the propriety of allowing defendants to litigate under a pseudonym in these matters,” its proposed order would not include any sealing or pseudonym provisions. It cited Chief Judge Bumb’s 2022 opinion. No order in that case discusses anonymity. Strike 3 filed the amended complaint on October 12, 2026 without redactions, which made the Strike 3 Holdings defendant name public at that stage. Our New Jersey and New York amended complaint post covers that case.

Northern District of Georgia (Atlanta Division): Judge Steven D. Grimberg

Judge Grimberg handles many Strike 3 Holdings cases in the Atlanta Division, consolidated under 1:23-cv-02096. When he allowed the first group of subpoenas on June 26, 2023, he noted that no protective order was needed at that point (1:23-cv-02096, ECF No. 10):

“The Court acknowledges Strike 3’s submission that it does not oppose a protective order; none is required at present. Any party seeking to maintain the confidentiality of any discovery may move to do so with the proper showing at any appropriate time during the pendency of these matters.— Judge Steven D. Grimberg, U.S. District Court for the Northern District of Georgia, Atlanta Division, Strike 3 Holdings, LLC v. John Doe, No. 1:23-cv-02096, ECF No. 10, Opinion & Order at 9 (June 26, 2023). Read the order (PDF)

Later sealing orders spell out the process. Strike 3 may file the unredacted amended complaint and summons under a provisional seal. The defendant then gets a short window after service to ask for protection. In 1:24-cv-04893, the order dated March 10, 2025 says (ECF No. 11):

“Within 30 days after service, Doe may move the Court to enter a protective order permitting him to proceed in this litigation under the pseudonym “Defendant 45.19.2.145.” If Doe declines to seek such relief, the Court shall dissolve the provisional sealing.— Judge Steven D. Grimberg, U.S. District Court for the Northern District of Georgia, Atlanta Division, Strike 3 Holdings, LLC v. John Doe, No. 1:24-cv-04893 (consolidated with 1:23-cv-02096), ECF No. 11, Order at 2–3 (Mar. 10, 2025). Read the order (PDF)

In other words, in Judge Grimberg’s cases the Strike 3 Holdings defendant name is public by default once the provisional seal ends, unless the defendant asks the court for protection in time. When a defendant has asked, the court has granted sealing in some cases.

Here is how that can end when no request comes in. In 1:25-cv-07314, the defendant was served on April 16, 2026 and did not ask to proceed under a pseudonym. On August 19, 2026, Judge Grimberg dissolved the provisional seal and directed the Clerk to add the defendant’s name to the case caption (ECF No. 13). That order made the Strike 3 Holdings defendant name public in that case. It explains:

“Defendant was personally served on April 16, 2026. To date, Defendant has not sought leave to proceed under a pseudonym. Accordingly, the provisional sealing imposed by the April 13 Order is DISSOLVED.— Judge Steven D. Grimberg, U.S. District Court for the Northern District of Georgia, Atlanta Division, Strike 3 Holdings, LLC v. John Doe, No. 1:25-cv-07314 (consolidated with 1:23-cv-02096), ECF No. 13, Order at 1 (Aug. 19, 2026) (footnotes omitted). Read the order (PDF)

A Settlement built on an Admission: New Jersey D.N.J. 1:21-cv-15638

The Camden case discussed above, 1:21-cv-15638, is worth a closer look, because the terms of the settlement became part of the court’s reasoning. A defense attorney (someone not affiliated with Antonelli Law) agreed to require the defendant to admit liability and also to accept a consent judgment with an injunction. The parties then jointly asked the court to enter that consent judgment and to keep the defendant anonymous. On October 26, 2022, Chief Judge Renée Marie Bumb, then a district judge, denied the request without prejudice (ECF No. 24, order).

The admission by the Defendant that he did what Strike 3 accused him of doing (committing copyright infringement) mattered when the court considered whether to make the Strike 3 Holdings defendant name public. The defendant’s identity had been kept confidential earlier in the case, but the opinion explains why that protection no longer applied:

“While it is true that Defendant’s identity has been kept confidential thus far in the litigation, such relief was only granted initially to “impose safeguards to protect the privacy rights of potentially innocent parties.” … But that is no longer a concern, as Defendant has now admitted to the underlying copyright infringement.— Chief Judge Renée Marie Bumb (then U.S. District Judge), U.S. District Court for the District of New Jersey, Strike 3 Holdings, LLC v. John Doe, No. 1:21-cv-15638, ECF No. 23, Opinion at 15–16 (Oct. 26, 2022) (citation omitted). Read the opinion (PDF)

No renewed consent motion was filed after that order. Instead, on November 29, 2022, the parties filed a notice of settlement and stipulation of dismissal with prejudice (ECF No. 25). The stipulation rests on the defendant “having admitted liability, D.E. 19,” and “having further represented Defendant’s compliance with all of the provisions of the proposed consent order, D.E. 20-4.” That filing also put the defendant’s real name on the public record, which made the Strike 3 Holdings defendant name public in that case. The Clerk terminated the case on November 30, 2022. Read the stipulation (PDF)

Settling without an admission or an injunction

Antonelli Law® has never had a client admit to committing the infringements to settle a case with Strike 3 Holdings – or any other copyright holder.  We also do not have clients agree to an injunction or a consent judgment to settle. Yes, we’ve been asked to do so. Admitting liability and agreeing to an injunction is rarely in a client’s interest, and as 1:21-cv-15638 shows, an admission on the record can weigh against keeping a name private when a judge decides whether to make a Strike 3 Holdings defendant name public.

Our settlement agreements never put the client’s name in the agreement. We identify the client the same way the federal court does. The release covers the person, not just the IP address, and it releases the client from all liability for activity before the settlement date.

Choosing experienced counsel matters wherever you are in the country. Antonelli Law® represents clients nationwide in federal court, and we also defend Strike 3 Holdings cases in court. If you are wondering whether your judge could make the Strike 3 Holdings defendant name public, we can review your documents and explain your options calmly.

What this means if you received an ISP letter

These rulings come from two separate federal courts: the District of New Jersey and the Northern District of Georgia. They do not mean every judge will rule the same way. Many judges still let Strike 3 defendants stay anonymous. Knowing whether your judge tends to make the Strike 3 Holdings defendant name public can help you and your attorney plan calmly, while the case still names only an IP address.

Most people who contact us want a quiet, anonymous resolution. Antonelli Law® never puts the client’s name in the settlement agreement. We identify the client the same way the federal court does, and our releases cover the person, not just the IP address. For more detail, read our guide to a Strike 3 Holdings anonymous settlement. We also defend Strike 3 Holdings cases in federal court when that is the right path.

If you just received a letter from your provider, the Strike 3 Holdings ISP letter guide walks through the first steps, and the Strike 3 Holdings FAQ answers common questions.

Talk with an attorney who handles these cases

Paul Sanders is one of the Antonelli Law® attorneys who reviews Strike 3 Holdings ISP letters, amended complaints, and questions about when a judge may make the Strike 3 Holdings defendant name public. Here is what one of his clients wrote.

Paul Sanders

“This experience was one of the most stressful experiences I have ever dealt with. Mostly because it came out of no where and I have never been in trouble with the law like this before. From the beginning, Mr. Sanders was so nice and calming. I know he stayed on the phone with longer than he had to just to make sure I was ok. Although I remained stressed, he put me at ease with his knowledge, confidence, and sincerity. The entire process took about 2 1/2 weeks and I was so grateful when it was over. He is a great attorney.”

Posted by anonymous | October 14, 2025 | Hired Attorney

→ View original review on Avvo

Paul Sanders’ bio

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Strike 3 Holdings defendant name public: FAQ

Is a Strike 3 Holdings defendant name public when the case is filed?

No. The complaint names a John Doe subscriber identified only by an IP address. The name usually comes up later, after the ISP responds to the subpoena and Strike 3 Holdings files an amended complaint.

Can a judge make the Strike 3 Holdings defendant name public after a settlement?

It has happened. In 1:21-cv-15638 in the District of New Jersey, the parties settled after the amended complaint and jointly asked to keep the defendant anonymous. Chief Judge Renée Marie Bumb denied that request without prejudice. No renewed request was filed, and the case ended in November 2022 with a stipulation of dismissal that made the Strike 3 Holdings defendant name public. Many people resolve their case earlier, while it still names only an IP address.

Do most judges let Strike 3 defendants stay anonymous?

In many courts, yes. Many orders that allow the ISP subpoena also let the defendant proceed as John Doe unless the court orders otherwise. A smaller group of judges, including judges in the District of New Jersey and the Northern District of Georgia, have required more before a name stays out of the public record.

What does Judge Grimberg in the Northern District of Georgia do?

In his Strike 3 Holdings cases, the unredacted amended complaint and summons stay under a provisional seal until service. The defendant then has 30 days to ask for a protective order to proceed under a pseudonym. If the defendant does not ask, the court dissolves the provisional seal. In August 2026, for example, he dissolved the seal in 1:25-cv-07314 and the defendant’s name was added to the case caption, which made that Strike 3 Holdings defendant name public.

Do you have to admit liability to settle with Strike 3 Holdings?

Antonelli Law® has never had a client admit to committing the infringements to settle a case with Strike 3 Holdings, and we do not have clients agree to an injunction or a consent judgment to settle. Admitting liability is rarely in a client’s interest, and it can weigh in favor of a court making the Strike 3 Holdings defendant name public. In 1:21-cv-15638 in the District of New Jersey, the settlement the defense in that case agreed to included an admission and an injunction, and the court relied on that admission when it declined to keep the defendant anonymous.

Does Antonelli Law® put my name in a settlement agreement?

No. Antonelli Law® never puts the client’s name in the settlement agreement. We identify the client the same way the federal court does, and the release covers the person, not just the IP address.

Can Antonelli Law® defend my case in court instead?

Yes. Most people who contact us want a quiet, anonymous resolution. We also defend Strike 3 Holdings cases in federal court when that is the right path.

Related reading

• Strike 3 Holdings anonymous settlement: does it release you personally?
• Strike 3 Holdings ISP letter guide
• Strike 3 Holdings FAQ
• Strike 3 Holdings amended complaints in New Jersey and New York
• Strike 3 amended complaint: what the later stage means

This page is general information about Strike 3 Holdings and similar BitTorrent copyright cases. It is not legal advice, and reading it does not create an attorney-client relationship. Court documents are linked so you can read each order in full. Client reviews describe individual experiences; past results do not guarantee a similar result. Antonelli Law® defends people and businesses against copyright claims and does not represent copyright holders. Attorney advertising.

TORRENT DEFENDERS® is a federally registered trademark owned exclusively by the Law Offices of Jeffrey J. Antonelli, Ltd.