Does Rule 15(c)(1)(C) categorically exclude relation back if the plaintiff initially used John Doe placeholders in the complaint due to inadequate knowledge regarding the defendants' names?

QUESTION PRESENTED Federal Rule of Civil Procedure 15(c)(1)(C) provides that when a plaintiff files an amended complaint changing the name of a defendant, that amendment relates back to the date of the original complaint if the newly named defendant (1) “received such notice of the action that it will not be prejudiced in defending on the merits” and (2) “knew or should have known that the action would have been brought against it, but for a mistake concerning the proper party’s identity.” The question presented is: Does Rule 15(c)(1)(C) categorically exclude relation back if the plaintiff initially used John Doe placeholders in the complaint due to inadequate knowledge regarding the defendants’ names?