¶ 11 The United States Supreme Court has held that the First Amendment to the United States Constitution protects a person's right to speak anonymously, Buckley v. Am. Constitutional Law Found., 525 U.S. 182, 199-200, 119 S.Ct. 636, 142 L.Ed.2d 599 (1999);  McIntyre v. Ohio Elections Comm'n, 514 U.S. 334, 341-51, 357, 115 S.Ct. 1511, 131 L.Ed.2d 426 (1995);  Talley v. California, 362 U.S. 60, 64-65, 80 S.Ct. 536, 4 L.Ed.2d 559 (1960), and that the protections of the First Amendment fully extend to speech on the internet, Reno v. Am. Civil Liberties Union, 521 U.S. 844, 870, 117 S.Ct. 2329, 138 L.Ed.2d 874 (1997).⁴  Because a court order is state action that is subject to constitutional restraint, courts have acknowledged that the issuance of discovery orders and subpoenas compelling disclosure of the identities of anonymous internet speakers raises First Amendment concerns.   See, e.g., Sony Music Entm't, Inc. v. Does 1-40, 326 F.Supp.2d 556, 563 (S.D.N.Y.2004);  2TheMart.com, 140 F.Supp.2d at 1091-92;  Dendrite Int'l, Inc. v. John Doe No. 3, 342 N.J.Super. 134, 775 A.2d 756, 760-61 (App.Div.2001);  Cahill, 884 A.2d at 456.   Recognizing the internet as a unique “democratic forum for communication,” one court concluded, “the constitutional rights of Internet users, including the First Amendment right to speak anonymously, must be carefully safeguarded.”  2TheMart.com, 140 F.Supp.2d at 1097.