The courts have long recognized that one can sue someone whose name is not known at the time of filing the action and then use the court's subpoena power to find out the person's name through an ISP. This practice has been in place since ISPs came into existence and it makes sense for the situation for which it was devised.

The problem here is that the mass-infringement actions have twisted this otherwise legitimate process into something warped and grossly unfair by using the name-gathering process to target people who are then told, "pay up or you will be exposed as a downloader of porn" (or, in other cases, you will be subjected to a major infringement lawsuit that is not worth defending).

Federal judges have enormous power and this judge (and many others) have simply said, "I won't let my court be used as an instrument for a shakedown," using legal niceties about jurisdiction to justify the matter formally. In effect, they are tossing the mass-infringement lawyers out the door, telling them their model won't work in their court. This is indeed the right outcome for this sort of abuse.