10 personal jurisdiction might properly be exercised over these Doe defendants is if they are residents of the District of Columbia or at least downloaded the copyrighted work in the District. See D.C. Code § 13-423(3), (4) (providing for personal jurisdiction over a person “causing tortious injury in the District of Columbia’); Nu Image, Inc. v. Does 1-—23,322, 799 F. Supp. 2d 34, 38-40 (D.D.C. 2011). But AF Holdings has made absolutely no effort to limit its suit or its discovery efforts to those defendants who might live or have downloaded Popular Demand in the District of Columbia. Instead, it sought to subpoena Internet service providers that provide no service at all in the District. As Duffy reluctantly conceded at oral argument, AF Holdings could have no legitimate reason for objecting to the court’s quashing the subpoenas directed at these providers. Oral Arg. Rec. 33:00— 04. Even for those providers that do serve the District of Columbia, AF Holdings’s discovery demands were overbroad because it made no attempt to limit its inquiry to those subscribers who might actually be located in the District. It could have easily done so using what are known as geolocation services, which enable anyone to estimate the location of Internet users based on their IP addresses. Such services cost very little or are even free. See Amicus Br. of Electronic Frontier Foundation, et al. 24 (observing that ““Neustar IP Intelligence . . . provides on-demand geolocation services for $8 per user’s street 1,000 addresses); see also http://freegeoip.net (last visited May 22, 2014) (providing this service for free). While perhaps not precise enough to identify an Internet address, these services “can be accurate,” as Duffy acknowledged at oral argument, Oral Arg. Rec. 23:58-24:01—certainly sufficiently accurate to provide at least some basis for determining whether a _ particular subscriber might live in the District of Columbia rather than, say, Oregon, see Nu Image, 799 F. Supp. 2d at 41 (‘while these geolocation services are not 100% accurate, these