INTRODUCTION :: Everyone “Googles” his or her own name once in a while. Imagine that a young woman looks herself up on the Internet one day, and finds that a person she does not know is posting offensive, false comments about her. These posts say that she enjoys having sex with family members, fantasizes about being raped by her parent, that she has a sexually transmitted disease and abuses heroin. That is precisely what happened to a female student at Yale Law School over many months. These and many other messages about this student were posted on the website AutoAdmit.com. Even after the woman filed her lawsuit, one particularly vicious poster, with the user name AK47, wrote that she “should be raped.” The plaintiff sent AT&T, the Internet Service Provider (ISP), a subpoena for information relating to the identity of the posters. The court granted the woman’s motion to engage in limited discovery, but AK47 (John Doe 21) filed a motion to quash the subpoena. He claimed that the subpoena violated his First Amendment rights.