Annemarie Bridy look at how the designers of P2P networks created a problem of scale in the form of “massive infringement.” Bridy discusses how to to approach solving that new problem of scale–massive infringement. She argues that the DMCA has proven to be remarkably scalable for enforcing copyrights in hosted content but has altogether failed to scale in the context of P2P file sharing, leading to the dysfunctional workaround of mass John Doe litigation. She discusses alternatives to mass litigation, including dispute resolution systems and “three strikes” proposals.