Though the Internet is often thought of as anonymous, this seeming anonymity has not done away with tort liability for defamatory pr libelous statements. While it is more difficult to find the identity of an anonymous Internet poster through an Internet IP address, new internet libel case law has established the appropriate procedures for subpoenaing the anonymous poster of defamatory statements. In Quixtar Inc. v. Signature Mgmt. Team, LLC, 2008 U.S. Dist. LEXIS 56593 (D. Nev., July 7, 2008, Decided), the US District Court of Nevada established a four-part test for subpoenaing an anonymous defamer.