Adopting a nine-factor balancing test for deciding when litigants may keep their real names secret, the 3rd U.S. Circuit Court of Appeals has ruled that pseudonyms should be reserved for those who can show a “reasonable” fear of “severe” harm.

In a rare move, the 3rd Circuit adopted as its own a test that was announced by the late U.S. District Judge Clarence C. Newcomer in his 1997 decision in Doe v. Provident Life and Accident Insurance Co.

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