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Pseudonyms allowedCivilTrial court
Doe v. Islamic Republic of Iran
- Court
- District Court, District of Columbia
- Decided
- Oct 2, 2026
- Docket
- Civil Action No. 2026-3308
- Judges
- Chief Judge James E. Boasberg
Detailed analysis & 3-line summary
AI breakdown
Where this case stands
This decision ·
Pseudonyms allowed
- This is the first court to decide the case, so there's no lower-court ruling.
TL;DR
- 1A well-known actor and his family are suing Iran, claiming intimidation and threats for his anti-government stance.
- 2The court decided they could proceed using pseudonyms in the lawsuit.
- 3This decision was based on concerns for their safety and the risks of retaliation.
Key issues
- 1
Can the plaintiffs proceed under pseudonyms?
Holding · Yes, the court allowed pseudonyms, balancing the plaintiffs' safety against public interest.
Why it matters
This decision affects individuals suing foreign governments, especially when personal safety and privacy are at risk.
If you were the judge?
Family sues Iran for alleged threats in the U.S.
- 1A famous actor and family sue Iran, claiming threats and attacks in the U.S.
- 2They say Iran targeted them for speaking out against its government.
- 3They want to sue without using their real names to stay safe.
Can the family sue Iran without using their real names?
Parties
Plaintiff
Doe
Defendant
Islamic Republic of Iran
Roles are inferred from the case caption.
Opinion of the court
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
VEINTE DOE, et al.,
Plaintiffs,
v. Civil Action No. 26-3308
ISLAMIC REPUBLIC OF IRAN, et al.,
Defendants.
MEMORANDUM OPINION AND ORDER
Born in Iran, Plaintiff Veinte Doe moved to the United States in 2016 and has been a
naturalized citizen since 2023. See ECF No. 1 (Compl.), ¶¶ 9â10. He is a well-known actor,
writer, and director who spoke out against the Islamic Republic of Iran on social media in 2022
and has since faced punishment and a campaign of intimidation and retaliation for his speech.
Id., ¶¶ 2â6. Plaintiff Veinte Uno Doe â who was born in Iran and naturalized as a citizen of the
United States in 2009 â is his wife. Id., ¶¶ 2, 12. Plaintiff Veinte Dos Doe is their son and was
born in California in 2013. Id., ¶¶ 2, 13.
In Plaintiffsâ telling, Defendants initially punished Veinte Doe in Iran, torturing him and
taking his relatives hostage to âcompel him to abandon his public criticism of the Islamic
Republic.â Id., ¶ 6. Afterward, they continued to pursue him and his family in the United States
through âproxies, intermediaries, and paid operatives, coordinated with a parallel campaign of
[media] vilification.â Id., ¶¶ 3, 5; see also ECF No. 4 (Mot.) at 3â4. For example, Plaintiffs
report a stone thrown through their window, confrontations in a supermarket, a car chase,
attempted vehicle collisions, verbal threats, physical interference with Veinte Dos Doe followed
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by a threatening note, and an arson plot targeting a cultural institute founded by Veinte Doe. See
Compl., ¶ 4; see also Mot. at 4â6.
Plaintiffs thus sued Iran for damages under the Foreign Sovereign Immunities Act, with
Veinte Dos Doe suing by and through his mother. See Compl., ¶ 13. They now move to proceed
pseudonymously. See generally Mot. The Court will grant their Motion.
I. Legal Standard
Generally, a complaint must identify the plaintiffs. See Fed. R. Civ. P. 10(a);
LCVR 5.1(c)(1). That requirement reflects the âpresumption in favor of disclosure [of litigantsâ
identities], which stems from the âgeneral public interest in the openness of governmental
processes,â and, more specifically, from the tradition of open judicial proceedings.â In re Sealed
Case, 931 F.3d 92, 96 (D.C. Cir. 2019) (quoting Wash. Legal Found. v. U.S. Sentencing
Commân, 89 F.3d 897, 899 (D.C. Cir. 1996)). A party moving to proceed pseudonymously thus
âbears the weighty burden of both demonstrating a concrete need for such secrecy[] and
identifying the consequences that would likely befall it if forced to proceed in its own name.â In
re Sealed Case, 971 F.3d 324, 326 (D.C. Cir. 2020). As a result, the court must âbalance the
litigantâs legitimate interest in anonymity against countervailing interests in full disclosureâ by
applying a âflexible and fact drivenâ balancing test. Id. (quoting In re Sealed Case, 931 F.3d at
96). That test assesses âfive non-exhaustive factorsâ:
(1) whether the justification asserted by the requesting party is
merely to avoid the annoyance and criticism that may attend any
litigation or is to preserve privacy in a matter of a sensitive and
highly personal nature;
(2) whether identification poses a risk of retaliatory physical or
mental harm to the requesting party or, even more critically, to
innocent non-parties;
(3) the ages of the persons whose privacy interests are sought to be
protected;
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(4) whether the action is against a governmental or private party;
and relatedly;
(5) the risk of unfairness to the opposing party from allowing an
action against it to proceed anonymously.
Id. at 326â27 (cleaned up).
II. Analysis
Plaintiffs have shown that their interest in pseudonymity outweighs the publicâs interest
in learning their identities.
First, as the Complaint makes clear, Plaintiffs do not seek to proceed under pseudonyms
âmerely to avoid the annoyance and criticism that may attend any litigation,â but to âpreserve
privacy in a matter of [a] sensitive and highly personal nature.â Id. at 326 (quoting In re Sealed
Case, 931 F.3d at 97) (alteration in original). Relevant here, privacy can include âmaintaining
[Plaintiffsâ] and their family membersâ safety.â Sponsor v. Mayorkas, 2023 WL 2598685, at *2
(D.D.C. Mar. 22, 2023); see also R.A. v. Islamic Republic of Iran, No. 23-2606, ECF No. 4
(Mem. Op. & Order) at 3 (D.D.C. Sept. 12, 2023) (determining that history of âsevere violence
and threats . . . at the hands of proxy militia organizationsâ shows that âPlaintiffs seek to avoid
much graver harms than mere annoyance and criticismâ).
Plaintiffsâ aforementioned allegations of violence and threats against them and their
relatives â including torture and detention in Iran and threats on the childâs life in the United
States, see Mot. at 7; Compl., ¶¶ 4, 6 â are more than sufficient to tip this first factor in their
favor. In particular, their pleadings demonstrate that they have an interest in âpreserving privacy
to protectâ the familyâs âsafety from third-party proxiesâ who âmight seek to harm Plaintiff[s] on
their own accord,â not just at the direction of Defendants. Farshid Do v. Islamic Revolutionary
Guard Corps, 2026 WL 980758, at *2 (D.D.C. Apr. 13, 2026); see Compl., ¶ 5 (â[T]hey used
proxies . . . coordinated with a parallel campaign of vilification . . . [that] marked [Veinte Doe]
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and his family for anyone willing to act.â) (emphasis added). In addition, as Plaintiffs note, the
sensitive nature of the information about Veinte Dos Doe, including descriptions of âthe
psychological effects of the [retaliation] campaign on him,â see Mot. at 8, lends their request
additional support under this factor.
The second factor â the risk of retaliatory harm â is closely related to the first and
likewise weighs in favor of pseudonymity. Plaintiffs allege that the conduct described above
was carried out in retaliation against Veinte Doeâs public criticism of the Iranian government.
See Compl., ¶¶ 60â96. Such âcampaign[s] against dissidents abroad,â they note, are well
documented. See Mot. at 8 (citing Elahi v. Islamic Republic of Iran, 124 F. Supp. 2d 97, 100â05
(D.D.C. 2000); and Bakhtiar v. Islamic Republic of Iran, 571 F. Supp. 2d 27, 30 (D.D.C. 2008),
affâd, 668 F.3d 773 (D.C. Cir. 2012)). Specific to their case, Plaintiffs allege that ânon-
defendant prox[ies]â continue to pursue them and that publicly identifying them in this litigation
would increase their âvisibilityâ and raise the risk of future harm to the whole family, including
relatives still living in Iran. Id. at 8â9. The ârisk of retaliatory . . . harm toâ Plaintiffs and âto
innocent non-partiesâ thus supports letting Plaintiffs proceed pseudonymously. In re Sealed
Case, 971 F.3d at 326 (quotation marks omitted).
The third factor also supports pseudonymity because disclosure of Plaintiffsâ names
would implicate the privacy interests or safety of a minor â namely, Veinte Dos Doe. Not only
would publication of his own name compromise his privacy and safety, but disclosure of his
parentsâ identities could do so, too. See R.A., Mem. Op. & Order at 4 (finding that this factor
favored motion âto some extentâ where âPlaintiffs indicate that one of them is a minor, and
revealing the other Plaintiffsâ identities risks undermining the anonymity of that personâ); see
also J. v. District of Columbia, No. 23-1279, ECF No. 3 (Mem. Op. & Order) at 4 (D.D.C. May
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9, 2023) (finding that this factor favored pseudonymity because adult Plaintiffs âshare common
privacy interests with their minor child due to their intractably linked relationshipâ) (cleaned up).
Factor four, the identity of the defendants, favors pseudonymity when a plaintiff sues a
government for individualized relief. Doe v. Rubio, 2025 WL 3522731, at *2 (D.D.C. Dec. 9,
2025). This suit fits the bill. Plaintiffs are suing the Islamic Republic of Iran and the Islamic
Revolutionary Guard Corps, see Compl., ¶¶ 16â28 â both governmental entities â as well as
officials, employees, agents, proxies, contractors, and intermediaries of said governmental
entities (Does 1â50). Id., ¶¶ 29â30. Furthermore, they seek compensatory, economic, and
punitive damages, id. at 29â30 (prayer for relief), which are forms of individualized relief.
Fifth and finally, letting Plaintiffs proceed pseudonymously will not prejudice
Defendants. Plaintiffs plan to file their true identities under seal for in camera inspection and
have acknowledged that âthe Court retains authority to order disclosure if circumstances
change.â Mot. at 11; see also J.K.A. v. United States, 2023 WL 12248425, at *3 (D.D.C. Aug.
10, 2023) (noting that when plaintiff offers to file identifying information under seal, this factor
supports pseudonymity). And to the extent that Defendants already know their identities, such
knowledge does not undercut Plaintiffsâ request for pseudonymity under this factor. See Mot. at
11â13; see also Doe v. Fed. Republic of Germany, 680 F. Supp. 3d 1, 6 (D.D.C. 2023)
(âDefendants would suffer no risk of unfairness if the Motion were granted, given Plaintiffâs
claim that they already know Plaintiffâs true identity.â) (cleaned up). Defendants thus do not
face a risk of unfairness. They remain free to request any further information they deem
necessary to the full defense of this case or to ask the Court to reconsider this decision.
The Court highlights that this is an initial decision to permit Plaintiffs to proceed
pseudonymously. If Defendants appear to defend this suit, the balance of factors might tip the
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other way. See Doe I v. Sabeti, 2025 WL 4348642, at *1 (M.D. Fla. Aug. 12, 2025)
(reconsidering initial grant to proceed pseudonymously in Torture Victim Protection Act case
upon defendant appearance). In any event, Plaintiffs have made an initial showing that their
concerns extend beyond Defendantsâ learning their identities to the risk that third parties could
obtain this information and act on Defendantsâ behalf to harm them. See Mot. at 12 (citing
Farshid Do, 2026 WL 980758, at *2).
In sum, all the factors weigh in favor of granting Plaintiffsâ Motion to Proceed Under
Pseudonym. The Court will thus grant Plaintiffsâ Motion, subject to reconsideration by the
District Judge to whom this case is randomly assigned.
The Court accordingly ORDERS that:
1. Plaintiffsâ [4] Motion for Leave to Proceed Under Pseudonym is GRANTED,
subject to any further consideration by the United States District Judge to
whom this case is randomly assigned;
2. All parties shall use the pseudonyms listed in the Complaint in all documents
filed in this action; and
3. Within fourteen days of this Order, Plaintiffs shall file:
i. A pseudonymous version of their [4] Motion on the public docket; and
ii. A sealed ex parte declaration containing their real names and
residential addresses.
/s/ James E. Boasberg
JAMES E. BOASBERG
Chief Judge
Date: October 2, 2026
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