Anonymous speech has a long and rich history in the US. As the Supreme Court has stated, it is plain that anonymity has sometimes been assumed for the most constructive purposes. Since the advent of the Internet, the anonymous speech doctrine has taken on an increasingly prominent role in society because anyone with Internet access can become a town crier or a pamphleteer. In early 2011, the Ninth Circuit addressed the conflict of anonymous speech in the Internet context in In re Anonymous Online Speakers. This case presented the issue whether the veil of anonymity could be pierced for five speakers' allegedly defamatory statements that were anonymously posted to various blogs. This note provides the facts and procedural history of the Ninth Circuit's decision in Anonymous Online Speakers. It summarizes the three main areas of analysis in the Ninth Circuit's opinion. Then it analyzes two major problems with the Ninth Circuit's decision.