Music companies shouldn’t break out the champagne quite yet. Last month a federal D.C. court ruled that Internet service provider Verizon is not required to turn over the names of members who anonymously swapped files; newly emboldened downloaders could return to illegal activity secure that they can’t be targeted. Also, warns Madden, the new crop of digital-music consumers who received MP3 players for the holidays could reverse the trend. “This isn’t the end of the story,” she says.