Meta’s Motion to Dismiss Strike 3 Holdings’ Copyright Lawsuit Is Denied

Posted by Steve Vondran | Aug 02, 2026

Strike 3 Litigation Updates - Meta must respond to infringement lawsuit: What the Court's Ruling Means for BitTorrent Defendants in California

Meta Invokes the Same IP-Address Defense Used by Thousands of Strike 3 Defendants—but the Court Finds “Something More”

For years, Strike 3 Holdings, LLC has filed copyright infringement lawsuits against individual internet subscribers accused of downloading and sharing adult films through the BitTorrent protocol.

Those cases usually begin with an IP address.

Strike 3 identifies an IP address through its proprietary monitoring system, files a lawsuit against an anonymous “John Doe,” obtains permission to subpoena the internet service provider, and then seeks the subscriber's identity. Once the ISP produces that information, the subscriber may receive a settlement demand or face the possibility of being named publicly in federal court.

One of the most important defenses in these cases is simple:

An IP address is not a person.

The Ninth Circuit recognized that principle in Cobbler Nevada, LLC v. Gonzales, holding that a person's status as the subscriber associated with an allegedly infringing IP address does not, standing alone, create a reasonable inference that the subscriber personally committed copyright infringement.

In an extraordinary reversal of roles, Meta Platforms, Inc. relied on that same principle when it moved to dismiss a copyright lawsuit filed against it by Strike 3 Holdings and Counterlife Media.

Meta essentially argued that an IP address is not a corporation, either.

On June 11, 2026, however, United States District Judge Eumi K. Lee denied Meta's motion to dismiss. The court did not reject Cobbler Nevada. Instead, it concluded that Strike 3 had alleged the “something more” that Cobbler Nevada requires—namely, an asserted pattern of coordinated downloading across Meta-associated corporate IP addresses and third-party cloud infrastructure.

The decision is important, but it must be understood carefully. It does not mean Meta infringed anyone's copyrights. It does not establish that Strike 3's monitoring evidence is accurate. It does not eliminate the IP-address defense available to residential defendants.

It means only that Strike 3 pleaded enough factual allegations to proceed into discovery.

What Is Strike 3 Holdings, LLC v. Meta Platforms, Inc.?

The case is:

Strike 3 Holdings, LLC and Counterlife Media, LLC v. Meta Platforms, Inc., Case No. 5:25-cv-06213-EKL, pending in the United States District Court for the Northern District of California.

Strike 3 and Counterlife allege that Meta used BitTorrent to download and upload their copyrighted films, allegedly in connection with Meta's development of generative artificial intelligence systems.

The plaintiffs alleged that their investigation identified:

47 Meta corporate IP addresses allegedly involved in 157 instances of torrenting;
multiple third-party IP ranges allegedly operating in coordination with Meta's addresses;
virtual private cloud infrastructure allegedly associated with Meta;
downloading patterns that allegedly suggested automated, keyword-driven data collection; and
thousands of copyrighted works allegedly implicated in the broader activity.

Meta disputed both the factual and legal sufficiency of those allegations and moved to dismiss all theories of liability under Federal Rule of Civil Procedure 12(b)(6).

What Arguments Did Meta Make in Its Motion to Dismiss?

Meta sought dismissal of the plaintiffs' claims for:

direct copyright infringement;
vicarious copyright infringement; and
contributory copyright infringement.

Meta's central theme was that Strike 3 had assembled a speculative narrative from IP-address records, unrelated torrent activity, and information arising from separate litigation concerning Meta's use of text datasets.

According to Meta, those allegations did not plausibly establish that Meta itself copied Strike 3's films, directed anyone else to do so, knew about the alleged activity, or financially benefited from it.

Argument No. 1: A Meta IP Address Does Not Establish That Meta Was the Infringer

Meta's strongest argument relied on Cobbler Nevada v. Gonzales.

Meta argued that Strike 3's identification of corporate IP addresses did not establish who actually used those addresses. Thousands of employees, contractors, vendors, visitors, and other users could potentially access Meta's internet infrastructure.

Accordingly, Meta argued, the fact that torrent activity was associated with a Meta-registered IP address did not permit a reasonable inference that Meta—as a corporate entity—performed or authorized the activity.

Meta cited the Ninth Circuit's statement that a subscriber's status as the registered user of an infringing IP address, standing alone, does not create a reasonable inference that the subscriber is the infringer.

Meta also argued that the alleged downloads were sporadic. The complaint identified 157 downloads involving 47 Meta corporate IP addresses over approximately seven years. Meta characterized this as isolated personal activity more consistent with unauthorized downloading by unidentified individuals than a coordinated corporate program.

Argument No. 2: Strike 3 Did Not Plausibly Allege Volitional Conduct by Meta

Direct copyright infringement requires more than a technical connection between a defendant's equipment and an infringing transmission.

Under Ninth Circuit authority, a plaintiff must allege causation or “volitional conduct”—conduct by the defendant that can reasonably be described as the direct cause of the infringement.

Meta argued that Strike 3 had not identified:

who allegedly initiated the downloads;
who allegedly selected Strike 3's films;
who allegedly programmed any downloading system;
who instructed anyone to use BitTorrent;
how Meta's officers or management supposedly participated;
where the files allegedly went;
whether the files were incorporated into an AI-training dataset; or
whether Meta's AI models were ever trained on Strike 3's works.

Meta contended that the complaint merely assumed that because Meta had previously used BitTorrent to acquire text datasets, any BitTorrent activity involving Meta-related infrastructure must also have been part of a corporate AI-training project.

Meta argued that this reasoning was speculative and did not adequately plead a volitional act by Meta.

Argument No. 3: The Separate Book-Torrenting Allegations Did Not Establish Film Infringement

The complaint relied in part on disclosures from separate litigation involving Meta's acquisition of text datasets for its LLaMA models.

Meta acknowledged that personnel had used BitTorrent to acquire portions of certain text datasets. But Meta argued that the use of BitTorrent for books did not plausibly establish that it also downloaded Strike 3's adult films.

The relevant works, purposes, data types, time periods, and personnel were different.

Meta therefore argued that allegations arising from separate AI-training litigation could not substitute for specific allegations connecting Meta to Strike 3's films.

Argument No. 4: Adult Films Allegedly Would Not Have Been Useful to Meta's AI Products

Meta argued that Strike 3's proposed motive did not make sense.

According to Meta, its AI-use policies prohibited generating pornographic content. Meta therefore argued that downloading adult films for AI training would have been inconsistent with its products and policies.

Meta also challenged the chronology. It argued that portions of the alleged torrenting activity did not align with the timing of Meta's development of relevant video-generation models.

Meta maintained that the more plausible explanation was isolated personal downloading by individuals rather than a centrally directed AI-training effort.

Judge Lee ultimately determined that these competing explanations could not be weighed in Meta's favor on a motion to dismiss.

Argument No. 5: Strike 3's Downloading-Pattern Evidence Was Methodologically Unexplained

A critical component of Strike 3's complaint was Exhibit B, which allegedly compared torrent activity across different IP addresses and networks.

Meta argued that the court should not rely on the exhibit because:

Strike 3 did not adequately explain its methodology;
the exhibit included downloads of many works not owned by Strike 3;
correlations between file names did not prove common control;
repeated or overlapping downloads could have innocent explanations;
the plaintiffs selectively presented information; and
the asserted relationships between IP ranges were speculative.

Meta contended that Strike 3's analysis amounted to “hunting and pecking” through a large dataset to locate coincidental similarities.

The court rejected that argument at the pleading stage, explaining that challenges to Strike 3's methodology were premature on a Rule 12(b)(6) motion.

That does not mean the methodology has been validated. It means Meta will need to challenge it through discovery, expert testimony, summary judgment, or trial rather than obtaining dismissal based solely on the pleadings.

Meta's Vicarious-Infringement Arguments

Vicarious copyright infringement generally requires allegations that the defendant:

possessed the right and ability to supervise or control the direct infringement; and
had a direct financial interest in the infringing activity.

Meta challenged both elements.

Argument No. 6: Meta Did Not Control the Alleged Infringers

Meta argued that Strike 3 had not identified any direct infringer or established that the person acted within the scope of employment.

The mere fact that someone may have used Meta's internet connection, computers, servers, or cloud resources was not enough, Meta argued, to show that Meta had a practical ability to supervise the specific torrenting activity.

Meta contended that internet access available to employees, contractors, or visitors did not transform Meta into the supervisor of every file transfer occurring over its networks.

It also argued that Strike 3 had not adequately connected the third-party cloud IP addresses to Meta's control.

Argument No. 7: Strike 3 Did Not Allege a Direct Financial Benefit

Meta argued that Strike 3 had not plausibly connected the alleged infringement to any financial gain.

Strike 3 asserted that its films could provide advantages in training AI models and that Meta expected substantial future revenue from AI products. Meta responded that generalized allegations about future AI revenue did not establish that the availability of Strike 3's particular films attracted customers or increased Meta's profits.

Meta also argued that avoiding licensing fees is not, by itself, the type of direct financial benefit required for vicarious infringement under Ninth Circuit law.

On this specific point, the court agreed that avoiding licensing fees alone would not satisfy the financial-benefit element. But the court accepted, at the pleading stage, Strike 3's broader theory that a larger and more varied training dataset could improve an AI product's capabilities and commercial value.

Meta's Contributory-Infringement Arguments

Contributory copyright infringement generally requires:

knowledge of another person's infringement; and
inducement of or material contribution to that infringement.

Meta argued that neither element was adequately pleaded.

Argument No. 8: Meta Did Not Have Actual Knowledge of Specific Infringement

Meta argued that contributory liability requires actual knowledge of specific infringement or facts supporting a plausible claim of willful blindness.

It contended that Strike 3 had not identified:

which Meta personnel supposedly knew about the torrenting;
when they learned about it;
which particular works they knew were being infringed;
what notices Strike 3 allegedly sent;
what technical information those notices included;
whether the alleged activity continued after notice; or
whether the allegedly infringing material was stored on systems Meta could locate or control.

Meta argued that generalized allegations that it “should have known” about internet activity were insufficient.

Argument No. 9: Cobbler Nevada Also Rejected a Duty to Police an Internet Connection

Meta did not rely on Cobbler Nevada solely for the proposition that an IP subscriber is not necessarily the infringer.

It also relied on Cobbler Nevada's rejection of contributory liability based merely on a subscriber's failure to police an internet connection.

In Cobbler Nevada, the Ninth Circuit held that an allegation that the defendant failed to secure, monitor, or police his internet service did not sufficiently connect him to the infringement.

Meta argued that the same principle applied to its corporate network. It maintained that imposing liability because it failed to monitor every download by every employee, contractor, visitor, or vendor would improperly create a broad duty to surveil internet usage.

Meta further argued that monitoring every file transferred over a global corporate network would be extraordinarily complicated and invasive—not a “simple measure” that copyright law required it to undertake.

Argument No. 10: Meta Did Not Materially Contribute to or Induce Infringement

Meta argued that providing general-purpose internet access, servers, cloud infrastructure, or computers does not establish inducement.

It contended that those technologies have overwhelming lawful uses and were not designed or promoted for copyright infringement.

Meta also argued that Strike 3 had not identified any affirmative communication encouraging infringement or any practical, simple measure that Meta could have taken to stop specific infringement after acquiring actual knowledge.

In Meta's view, the complaint described ordinary technological infrastructure, not an infringement-inducing service.

The Court Denies Meta's Motion to Dismiss

Judge Lee denied the motion in its entirety, finding that Strike 3 had plausibly pleaded direct, vicarious, and contributory copyright infringement.

The court repeatedly emphasized the procedural posture.

A Rule 12(b)(6) motion does not determine whether the allegations are true. The court must generally accept well-pleaded factual allegations as true and draw reasonable inferences in the plaintiff's favor.

Meta may ultimately disprove Strike 3's allegations. But at the motion-to-dismiss stage, the court concluded that Strike 3's asserted downloading patterns supported a plausible inference of coordinated activity.

The Court's Deep Dive on Cobbler Nevada v. Gonzales

What Happened in Cobbler Nevada?

In Cobbler Nevada, LLC v. Gonzales, 901 F.3d 1142 (9th Cir. 2018), the plaintiff traced alleged BitTorrent infringement to an IP address registered to Thomas Gonzales.

Gonzales operated an adult foster-care home. Multiple residents and other individuals could access the internet connection.

The copyright plaintiff alleged that Gonzales was liable because:

he was the registered subscriber;
the infringement occurred through his IP address; and
he failed to secure or adequately police the connection.

The Ninth Circuit rejected both direct and contributory liability.

The appellate court explained that numerous individuals and devices can share a single IP address. Subscriber status alone therefore does not support a reasonable inference that the subscriber personally committed infringement.

The Ninth Circuit required “something more” linking the subscriber to the conduct.

It also rejected the theory that Gonzales became contributorily liable merely because he failed to monitor or police his internet service.

Why Cobbler Nevada Is So Important in Strike 3 Cases

Strike 3's standard litigation model begins with an IP address, not an identified human being.

That distinction matters because the subscriber could be different from the downloader.

Potential users may include:

a spouse;
an adult child;
a roommate;
a tenant;
a houseguest;
an employee;
a contractor;
a neighbor;
an unknown Wi-Fi user; or
another person who had access to the network or device.

Cobbler Nevada prevents a copyright plaintiff from simply assuming that the person who pays the internet bill must be the infringer.

That principle remains good law after the Meta decision.

Meta's Corporate Version of the Cobbler Nevada Defense

Meta attempted to apply Cobbler Nevada at a much larger scale.

Instead of a household with several possible users, Meta has thousands of employees, contractors, vendors, and visitors.

Its basic argument was:

The fact that torrenting allegedly occurred through a Meta IP address does not establish that Meta itself committed, caused, authorized, or knew about the infringement.

Judge Lee agreed with Meta's statement of the rule but concluded that Strike 3's complaint did not rely exclusively on subscriber status.

That distinction controlled the result.

What Was Strike 3's Alleged “Something More”?

The court found that Strike 3 alleged apparent coordination across the relevant IP addresses.

Among other things, Strike 3 alleged that different addresses downloaded files with similar terms in their file names on the same day.

One example involved files containing the word “teen,” including a mixture of adult content, cartoons, movies, and television programs. The court found that the pattern plausibly suggested an algorithm searching for and downloading files based on keywords.

The complaint also identified other asserted correlations involving words such as “dragon” and “bang.”

The court stated that it “strains credulity” to attribute all of the correlations to coincidence and independent human choices. It concluded that the allegations supported a reasonable inference that an automated system coordinated the downloads.

The court also considered alleged movement among different IP ranges, changes in file-name languages, repeated downloads of obscure files, and the asserted relationship between Meta corporate addresses and cloud infrastructure.

Taken together, the court found those allegations sufficient to meet Cobbler Nevada's “something more” requirement.

Did the Court Overrule or Weaken Cobbler Nevada?

No.

The court expressly applied Cobbler Nevada.

The ruling confirms two separate propositions:

An IP address alone is not enough.
An IP address plus additional facts plausibly linking the defendant to coordinated infringement may be enough to survive a motion to dismiss.

The decisive question is what constitutes “something more.”

For Meta, the alleged “something more” was a large-scale, cross-network pattern that the court believed could plausibly reflect an algorithmic data-gathering operation.

That is dramatically different from the typical Strike 3 residential case involving one household, one internet subscription, and one IP address.

Why the Meta Ruling Does Not Eliminate the IP-Address Defense for Individuals

Strike 3 may attempt to cite the Meta decision broadly, but the ruling is highly fact-specific.

The court relied on allegations involving:

dozens of corporate IP addresses;
multiple third-party IP ranges;
cloud infrastructure;
numerous allegedly correlated downloads;
common file-name keywords;
alleged algorithmic behavior;
a corporate AI-data-acquisition theory; and
information from separate litigation concerning Meta's use of BitTorrent.

A residential Strike 3 defendant ordinarily does not present anything close to that factual pattern.

In a standard California case, Strike 3 may have only:

one IP address;
an ISP subscriber's name;
alleged downloads associated with that IP address; and
an assertion that the subscriber is therefore likely the infringer.

Under Cobbler Nevada, that may not be enough.

The Meta decision therefore does not erase the defense. In an important sense, it reinforces it by showing how much additional factual matter the court required before allowing a claim to proceed against the subscriber or account holder.

The Court's Ruling on Direct Copyright Infringement

The court concluded that Strike 3 adequately alleged violations of the reproduction and distribution rights through BitTorrent downloading and uploading.

The court rejected Meta's argument that Strike 3 was required at this stage to establish that each film was actually used to train a particular AI model. The court reasoned that the alleged infringement occurred when the films were reproduced or distributed through BitTorrent, regardless of their ultimate use.

On causation, the court found the alleged downloading patterns sufficient to infer a coordinated data-gathering effort attributable to Meta.

The court therefore held that Strike 3 had pleaded the “something more” required by Cobbler Nevada.

The Court's Ruling on Vicarious Copyright Infringement

Right and Ability to Control

The court concluded that the complaint plausibly alleged that Meta employees performed the torrenting within the scope of their employment.

Based on that inference, the court found sufficient allegations that Meta had the legal and practical ability to supervise the conduct.

This conclusion depends heavily on accepting the plaintiffs' corporate-data-gathering theory as plausible.

If discovery ultimately shows that the downloads were personal, unauthorized, or unrelated to employment, the control analysis could change significantly.

Direct Financial Interest

The court rejected the theory that avoiding licensing fees alone constituted a direct financial benefit.

However, it accepted Strike 3's alternative theory that allegedly obtaining copyrighted works for an AI-training dataset could improve the quality and functionality of Meta's AI systems, attract users, and generate commercial revenue.

The court analogized the theory to A&M Records, Inc. v. Napster, Inc., reasoning that the value of an AI system may increase as the quantity and quality of its training data increase.

The court therefore found that Strike 3 had plausibly alleged a financial interest at the pleading stage.

The Court's Ruling on Contributory Copyright Infringement

Knowledge

The court found that Strike 3 had sufficiently alleged actual knowledge by asserting that Meta ordered or coordinated the use of BitTorrent.

The court relied again on the alleged downloading patterns and coordination across IP addresses.

Because it found actual knowledge adequately pleaded, the court did not decide whether Strike 3 had also sufficiently alleged willful blindness or effective post-infringement notice.

Inducement

During the motion's pendency, the Supreme Court issued its 2026 decision in Cox Communications, Inc. v. Sony Music Entertainment, clarifying the intent required for contributory infringement.

Judge Lee recognized that merely providing internet service or general-purpose technology would not be sufficient.

But she concluded that Strike 3 alleged more than passive infrastructure. According to the complaint, Meta allegedly implemented an algorithm and established virtual private clouds for a coordinated BitTorrent operation.

The court found those allegations sufficient to plead active inducement.

Because inducement was sufficiently alleged, the court did not separately decide whether Meta materially contributed to the alleged infringement.

What the Court Did Not Decide

The denial of a motion to dismiss is not a determination that:

Meta downloaded Strike 3's films;
Meta used the films to train an AI model;
Strike 3's forensic methodology is reliable;
the identified IP ranges were actually controlled by Meta;
the downloads were coordinated;
an algorithm performed the downloads;
Meta employees acted within the scope of employment;
Meta had actual knowledge;
Meta financially benefited from the activity; or
Strike 3 will ultimately prevail.

The court determined only that the complaint presented a plausible claim when its factual allegations were accepted as true.

Meta may challenge those allegations through:

written discovery;
depositions;
source-code and systems evidence;
cloud-account records;
forensic analysis;
expert testimony;
a motion for summary judgment; and
trial.

The court's order expressly noted that methodological challenges and competing factual inferences were premature at the pleading stage.

What Does the Meta Decision Mean for California Strike 3 Defendants?

1. Cobbler Nevada Remains a Powerful Defense

Strike 3 still cannot establish personal liability merely by identifying the ISP subscriber.

A defendant should carefully investigate every person, device, and network-access point associated with the relevant IP address.

The subscriber and the alleged infringer may be different people.

2. The Existence—or Absence—of “Something More” Matters

The critical inquiry is whether Strike 3 possesses evidence beyond the IP address.

Potential additional evidence could include:

admissions;
device-forensic findings;
matching file names;
BitTorrent software;
stored movie files;
browsing or search history;
account information;
repeated activity linked to a specific user;
highly individualized download patterns; or
other facts connecting a particular person to the alleged activity.

A defense lawyer should force Strike 3 to identify exactly what its “something more” is.

3. Corporate-Scale Coordination Is Different From Household Internet Use

The Meta case involved an alleged industrial-scale operation across numerous addresses and cloud networks.

A household case usually involves one shared connection.

Defendants should resist efforts to treat the Meta ruling as though it eliminated the distinction between an IP address and a human being.

4. Strike 3's Forensic Evidence Can Still Be Challenged

The court did not validate Strike 3's tracking system.

Important questions remain:

Did the monitoring system accurately identify the IP address?
Was the correct file hash captured?
Did the system obtain a complete copyrighted work or only fragments?
Was the alleged transaction independently verified?
Were clocks and timestamps synchronized?
Was the IP address dynamically assigned?
Did the ISP accurately match the address to the subscriber?
Could VPNs, proxies, shared networks, or compromised devices affect attribution?
Does Strike 3's investigator have admissible evidence establishing personal identity?
Can the methodology survive a Daubert challenge?

These issues are ordinarily not resolved on a motion to dismiss.

5. Defendants Should Not Contact Strike 3's Lawyers Without Counsel

Statements made to opposing counsel can become evidence.

Even seemingly harmless explanations can reveal:

household members;
device ownership;
travel dates;
internet habits;
security weaknesses;
possible alternative users;
admissions about BitTorrent software; or
facts that narrow Strike 3's investigation.

Communications should generally be handled through experienced defense counsel.

California Strike 3 Holdings Defense Attorneys

Vondran Legal has defended hundreds and hundreds of Strike 3 Holdings and other BitTorrent copyright cases over many years.

Our experience includes representing internet subscribers in federal copyright matters involving:

Strike 3 Holdings;
anonymous John Doe lawsuits;
ISP subpoena notices;
early-discovery proceedings;
motions to quash;
protective-order issues;
subscriber-identification disputes;
Cobbler Nevada defenses;
innocent-subscriber and misidentification defenses;
spouse, roommate, guest, tenant, and family-member scenarios;
unsecured or shared Wi-Fi;
forensic computer examinations;
preservation obligations;
settlement negotiations;
confidentiality concerns;
motions to dismiss;
answers and affirmative defenses;
discovery strategy; and
litigation through dismissal or resolution.

Our substantial California experience allows us to evaluate not merely the number of works listed in a complaint, but the actual strength of the attribution evidence.

Our California Strike 3 Defense Process

Immediate Deadline Review

ISP subpoena notices frequently contain short objection deadlines. We review:

the subpoena;
the federal docket;
the complaint;
the court's early-discovery order;
the ISP notice;
the alleged IP address;
the relevant timestamps; and
the number of works claimed.

Household and Network Investigation

We work with clients to understand:

who lived at the residence;
who had access to the network;
what devices were present;
whether children or adult family members used the connection;
whether guests, roommates, tenants, or employees had access;
whether Wi-Fi was secured;
whether the router was replaced;
whether the subscriber was traveling;
and whether the account holder personally used BitTorrent.

Cobbler Nevada Analysis

We evaluate whether Strike 3 has anything beyond subscriber identity.

The central question is often:

What evidence connects this particular person—as opposed to the IP address—to the alleged downloads?

Where Strike 3 lacks that connection, Cobbler Nevada may provide significant leverage.

Anonymous Settlement Negotiations

In appropriate cases, we may communicate with Strike 3's counsel while the defendant remains identified as a John Doe.

The objective is to protect privacy, avoid unnecessary public exposure, and determine whether a confidential resolution is advisable.

Litigation and Forensic Strategy

Where the facts support a defense, we evaluate:

motions to quash or modify;
protective orders;
challenges to joinder or venue;
motions to dismiss;
forensic inspections;
declarations from other potential users;
challenges to Strike 3's investigator;
expert analysis;
summary judgment;
and fee-shifting or sanctions issues where legally supported.

Why Experience Matters in Strike 3 Holdings Cases

Strike 3 cases are not ordinary copyright lawsuits.

They combine:

anonymous federal litigation;
technical BitTorrent evidence;
ISP subpoenas;
substantial statutory-damages allegations;
privacy concerns;
reputational pressure;
compressed deadlines;
and settlement strategies developed through thousands of similar filings.

An attorney unfamiliar with the litigation model may focus only on theoretical maximum damages.

An experienced Strike 3 defense lawyer evaluates:

whether the subscriber is actually the downloader;
whether Strike 3 has “something more” than an IP address;
the strength of the forensic evidence;
the number and timing of alleged works;
registration issues;
household facts;
litigation history;
settlement patterns;
judicial assignment;
and whether the case should be negotiated, challenged, or actively litigated.

Key Takeaways From Meta's Failed Motion to Dismiss

Meta's motion to dismiss was denied. Judge Lee held that Strike 3 plausibly alleged direct, vicarious, and contributory infringement.
The court did not reject Cobbler Nevada. It applied the decision and found that Strike 3 alleged “something more” than ownership of an IP address.
The alleged “something more” was coordinated downloading activity. The court relied on asserted common keywords, cross-network patterns, and other allegations suggesting algorithmic rather than independent human selection.
The ruling is procedural, not a finding of liability. Strike 3 must still prove its allegations through admissible evidence.
The ruling does not eliminate residential IP-address defenses. Typical household cases generally lack the extensive cloud and cross-network allegations asserted against Meta.
Strike 3's monitoring evidence remains open to challenge. The court found disputes about methodology premature, not meritless.
Subscribers should act before the ISP deadline. Ignoring the notice can increase the risk of being identified and publicly named.

Contact a California Strike 3 Holdings Defense Lawyer

Receiving a Strike 3 Holdings subpoena notice does not mean that Strike 3 has proven you downloaded anything.

It usually means Strike 3 has associated alleged BitTorrent activity with an IP address assigned to your internet account.

That is the beginning of the analysis—not the end.

Vondran Legal has handled hundreds and hundreds of BitTorrent and Strike 3 matters over many years and is a leading California law firm for Strike 3 Holdings defense.

We represent clients facing:

ISP subpoena notices;
anonymous federal lawsuits;
Strike 3 settlement demands;
copyright infringement complaints;
demands for forensic inspections;
and threatened public identification.

Early legal advice can help preserve defenses, protect privacy, evaluate Cobbler Nevada, and determine whether the matter should be challenged, negotiated, or litigated.

Nationwide IP Representation — California Strike 3 Holdings Defense

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