## Facts

- Record companies sued 27 unknown individuals identified only by Internet Protocol (IP) addresses, alleged to be users of the University of Maine network.
- Plaintiffs alleged each Doe used peer-to-peer (P2P) file-sharing software to download and make available copyrighted sound recordings without authorization.
- The complaint identified specific sound recordings and associated copyright ownership.
- The complaint alleged infringement tied to particular IP addresses with corresponding dates and times of the alleged P2P activity.
- Various Doe defendants moved to dismiss under Federal Rule of Civil Procedure 12(b)(6) and sought related relief, including discovery limitations and Rule 11 sanctions.
- A magistrate judge recommended denying dismissal; defendants objected, triggering de novo review by the district judge on the contested portions.

## Issues

1. Whether the complaint stated a plausible claim for copyright infringement under Rule 8(a) as interpreted by *Bell Atlantic Corp. v. Twombly*, sufficient to survive Rule 12(b)(6).
2. Whether allegations of copyright ownership and P2P “downloading” and “distribution” adequately pleaded violations of exclusive rights under 17 U.S.C. § 106.
3. Whether defendants were entitled to sanctions or other relief premised on the asserted insufficiency or impropriety of the pleading and investigation methods.

## Decision

- The court denied the Doe defendants’ Rule 12(b)(6) motions to dismiss.
- The court held the complaint contained enough nonconclusory factual content—identified works, IP addresses, and temporal data—to make infringement plausible.
- The court treated disputes about whether a particular Doe actually operated the computer at the relevant time as merits questions not suitable for resolution on a motion to dismiss.
- The court denied Rule 11 sanctions and rejected related defense requests to the extent they depended on the contention that the complaint was inadequately pleaded.
- The court allowed the case to proceed, including discovery aimed at identifying the anonymous defendants.

## Legal Principles

- Under Rule 8(a) and *Twombly*, a complaint must plead sufficient factual matter to state a claim that is plausible on its face; a formulaic recitation of elements is insufficient.
- A copyright infringement claim requires allegations of (1) ownership of a valid copyright and (2) violation of an exclusive right under 17 U.S.C. § 106 (including reproduction and distribution).
- At the pleading stage, detailed proof of each infringing transfer is not required if the complaint provides factual detail supporting a reasonable inference of infringement.
- Use of IP-address and timestamp allegations may provide fair notice and a plausible basis to proceed against anonymous defendants, with identity and user-specific questions typically developed through discovery.

## Conclusion

The court held that record companies plausibly pleaded P2P copyright infringement by alleging ownership, identified works, and IP-based, time-specific infringement facts, and it therefore denied dismissal and sanctions and permitted discovery to identify the anonymous defendants.


Arista Records LLC v. Does 1–27, 584 F. Supp. 2d 240 (D. Me. 2008)