London-Sire Records, Inc. v. Doe 1
United States District Court for the District of Massachusetts
542 F.Supp. 2d 153 (2008)
Peer-to-peer file-sharing software let users share exact digital copies of copyrighted music and video files, traceable only to an IP address rather than a specific individual, since ISPs often reassigned IP numbers across different computing sessions. London-Sire Records and other record companies (plaintiffs) sued 40 anonymous John Doe file-sharers for copyright infringement and subpoenaed ISPs for the users' identities; three John Does moved to quash the subpoenas, arguing disclosure would violate their First Amendment rights to anonymous speech and creative expression, and separately that London-Sire hadn't even pleaded an actionable copyright harm, since copyright distribution rights supposedly covered only actual distribution of tangible physical objects and merely making files available for sharing didn't count as distribution.
Whether a copyright owner's exclusive right to distribution is limited only to the distribution of physical objects.