In Hadley v. Doe, 34 N.E.3d 549 (Ill. 2015) (No. 118000), plaintiff alleged that defendant, an unidentified internet user, had posted defamatory statements on a newspaper internet message board.  Plaintiff requested that the court order defendant’s internet service provider to disclose defendant’s identity; the court granted the request and the appellate court affirmed.  The Illinois Supreme Court also affirmed.  The court noted that under Illinois rules, a plaintiff may obtain discovery for purposes of discovering the identity of an unidentified individual who may be liable to him, provided that plaintiff can demonstrate that discovery of the individual’s identity is “necessary.”  The court ruled that to demonstrate necessity, the plaintiff must present sufficient allegations to survive a motion to dismiss, reasoning that this standard struck the right balance of protecting a plaintiff’s right to redress for defamatory statements and protecting against a disclosure standard that is so low that it effectively chills the right to speak anonymously.  The court concluded that a more stringent standard was not required because, once a plaintiff establishes a prima facie case for defamation, there are no first amendment concerns because a potential defendant has no first amendment right to defame.