In the internet environment, copyright enforcement often begins with filing a John Doe suit against unknown infringers identified by IP addresses, figuring out which ISP owns those addresses, and then obtaining information from the ISP about the identity of a particular subscriber.  In Killer Joe Nevada v. Leaverton, the Eight Circuit held that a district court did not abuse its discretion in refusing to award attorneys’ fees when a copyright plaintiff voluntarily dismissed a case against a particular individual that was identified by IP address.