TCYK, LLC v. Does 1-88, No. 13 C 3828, Slip Op. (N.D. Ill. June 24, 2013) (Guzman, J.).

Judge Guzman sua sponte severed Does 2-88 pursuant to Fed. R. Civ. P. 20 & 21 in this Bit Torrent copyright case.  Because the Does were not all part of the same “swarm” at the same time - although they were part of the same swarm - joinder was not proper pursuant to Rule 20.

Even if Rule 20 joinder was proper, the Court would have exercised its Rule 21 discretion to sever the eighty eight Does, quoting 101 Doe case as a “logistical nightmare.”  Pacific Century International, Ltd. v. Does 1-101, No. C-11-02533 (DMR), 2011 WL 5117424, at *3 (N.D. Cal. Oct. 27, 2011).