Simply put, yes. The Wisconsin Supreme Court recognized that anonymous speech on the Internet requires a measure of protection against abuse of the discovery process to uncover the identity of the anonymous speaker. To that end, it held that Wisconsin courts must first “decide a motion to dismiss before compelling disclosure [of identifying information] and imposing sanctions,” thus ensuring that any underlying defamation claims have merit before allowing anonymous speakers to be unmasked.
For example, a state politician filed a claim against a combination of known and anonymous defendants who had sent out defamatory political mailers about her during an election cycle, seeking to unmask the defendants. The Supreme Court upheld the lower court’s judgment in favor of the politician, citing the defendants’ failure to argue for a ruling on the motion to dismiss before allowing discovery. Lassa v. Rongstad, 2006 WI 105.