Second Time’s The Charm: Hellboy Obtains Norwich Order In Copyright Infringement Proceeding

In Hellboy Productions, Inc. v. Doe #1,¹ the Federal Court granted the second attempt by Hellboy Productions Inc. (the Plaintiff) at a motion for a Norwich order, requiring a non-party Internet Service Provider (ISP) to identify the owners of IP addresses used to share the Plaintiff’s film online. The decision is a helpful reminder of the evidentiary requirements on a motion for a Norwich order.

Background: The Plaintiff’s First Attempt

The underlying action is for infringement of copyright in the Plaintiff’s film, Hellboy: The Crooked Man (the Film). It names over 2,400 unknown defendants (the Doe Defendants), each identified by their internal protocol (IP) address. In 2025, the Plaintiff moved for Norwich orders against non-party ISPs, seeking to identify the owners of those IP addresses. The Motions Judge held that the Plaintiff failed to establish a bona fide claim of copyright infringement and to connect the ISPs to the Doe Defendants and therefore dismissed the motion.