Doe et al v. Inflection Risk Solutions, LLC

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
JANE DOE, et al.,
Plaintiffs,
v.
INFLECTION RISK SOLUTIONS, LLC,
Defendant.
Case No. 26-cv-10976-AGT
ORDER ON MOTION FOR LEAVE
TO PROCEED UNDER PSEUDO-
NYMS
Re: Dkt. No. 2
Plaintiffs seek leave to proceed under pseudonyms. Dkt. 2. The Court grants their
request, without prejudice to revisiting the issue at a later date.
Parties must typically use their real names in litigation. Doe v. Kamehameha
Sch./Bernice Pauahi Bishop Estate, 596 F.3d 1036, 1046 (9th Cir. 2010). However, a party
may proceed under a pseudonym “when the party’s need for anonymity outweighs prejudice
to the opposing party and the public’s interest in knowing the party’s identity.” Does I thru
XXIII v. Advanced Textile Corp., 214 F.3d 1058, 1068 (9th Cir. 2000). One situation where
pseudonyms may be appropriate is when anonymity is necessary “to preserve privacy in a
matter of sensitive and highly personal nature.” Id. (citation omitted).
Plaintiffs’ criminal records have been sealed under Pennsylvania law; they allege
that Defendant unlawfully disclosed these records in reports to potential landlords. Dkt. 2 at
2. Plaintiffs argue that without pseudonyms, their sealed criminal history will be publicly
tied to them. Id. Plaintiffs fear that they’ll be stigmatized due to this disclosure and suffer
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economic and reputational harm. Id. They also say that litigating this case under their true
names would perpetuate their alleged injury and force them to give up the benefits of a sealed
record. Id.
The Court isn’t entirely convinced that pseudonymity is appropriate here. On one
hand, the kind of economic and reputational harm that Plaintiffs raise may not sufficiently
justify the use of pseudonyms under Ninth Circuit law. Plaintiffs cite no Ninth Circuit prec-
edent permitting pseudonyms in a case involving this kind of disclosure of criminal history;
in at least one case, a district court within the Circuit has denied a similar request. Doe v.
Rentgrow, Inc., Case No. 2:23-cv-00860-ART-EJY, 2023 WL 6541998 (D. Nev. Aug. 3,
2023) (denying motion to proceed under pseudonym in case alleging disclosure of expunged
conviction in a tenant screening report).
On the other hand, however, courts within this district have recognized that “the most
compelling situations” for use of a pseudonym include those where “the injury litigated
against would occur as a result of the disclosure of the plaintiff’s identity.” In re Meta Pixel
Healthcare Litigation, Case No. 22-cv-03580-WHO, 2025 WL 807954, at *1 (N.D. Cal.
Mar. 12, 2025). Similarly, “[r]equiring plaintiffs who seek to vindicate their privacy rights
to publicly link their names to the information they seek to protect – allegedly sensitive
information that has not already been widely disclosed – is against the public interest, as it
could dissuade plaintiffs from bringing privacy cases.” Id. at *2. Both of these concerns are
implicated here. More practically, the use of pseudonyms likely won’t prejudice Defendant,
because Plaintiffs intend to disclose their identities to Defendant under a protective order.
Dkt. 2 at 6.
/ / /
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The Court concludes that the balance of factors tips in Plaintiffs’ favor at this stage
of the case. If Defendant wishes to raise the issue after it appears, the Court will reconsider
it with the benefit of adversarial briefing. Alternatively, the parties might reach agreement
on this issue or another mechanism, such as a protective order, that adequately addresses
Plaintiffs’ privacy concerns. Plaintiffs’ motion is therefore granted, without prejudice to the
issue being raised later.
IT IS SO ORDERED.
Dated: October 8, 2026
______________________________
Alex G. Tse
United States Magistrate Judge
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