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The Virginia Geofence Warrant. While New York has proposed the first bill outlawing these warrants,182182. We looked for any warrant described as targeting . The fact that geofence results indicate only proximity to a crime, not whether someone broke the law or is even suspected of wrongdoing, has also alarmed legal scholars, who worry it could enable government searches of people without real justification. The warrants constitutional defect its generality is cured by its spatial and temporal restrictions, even though the warrant still names no individualized suspect. The . The time and place of the crime are necessarily known by law enforcement, giving rise to probable cause to search the relevant area. Jake Laperruque, Project on Government Oversight, Torn between the latest phones? About a month after the robbery, state law enforcement officials obtained a geofence warrant from . Ct., 387 U.S. 523, 528 (1967). Because geofence warrants are a new law enforcement tool, there is no collection of data or guidance for oversight. See United States v. Jones, 565 U.S. 400, 402 (2012); United States v. Karo, 468 U.S. 705, 709, 717 (1984). Complaint at 23, Rodriguez v. Google, No. Google received more than 20,000 geofence warrants in the US in the last three calendar years, making up more than a quarter of all warrants the tech giant received in that time . Because it is rare to search an individual in the modern age. In the probable cause context, time should be treated as just another axis like latitude and longitude along which the scope of a warrant can be adjusted. Rep. 807 (KB); and Money v. Leach (1765) 97 Eng. Government practice further suggests that the search begins when companies look through their entire databases. Ninety-six percent of Americans own cell phones. But there is nothing cursory about step two. See id. In most cases, the information is in the form of latitude and longitude coordinates derived . for Just., Cellphones, Law Enforcement, and the Right to Privacy 5 (2018), https://www.brennancenter.org/sites/default/files/2019-08/Report_Cell_Surveillance_Privacy.pdf [https://perma.cc/Z6F7-XZYV]. For a discussion of the Carpenter Courts treatment of the third party doctrine, see Laura K. Donohue, Functional Equivalence and Residual Rights Post-Carpenter: Framing a Test Consistent with Precedent and Original Meaning, 2018 Sup. Typically, a geofence warrant calls on Google to access its database of location information. See Google Amicus Brief, supra note 11, at 10; see also Carpenter, 138 S. Ct. at 2218 (recognizing that high technological precision increases the likelihood that a search exists); United States v. Beverly, 943 F.3d 225, 230 n.2 (5th Cir. This Part argues that the relevant search for Fourth Amendment purposes occurs instead when a private company first searches through its entire database step one in Googles framework and that, as a result, geofence warrants are categorically unconstitutional. Police around the country have drastically increased their use of geofence warrants, a widely criticized investigative technique that collects data from any user's device that was in a specified area within a certain time range, according to new figures shared by Google. It is clear that technology will only continue to evolve. If, instead, step two constitutes the search, law enforcement should not be able to seek additional location information about any users provided without either an additional warrant or explicit delineation of this second search in the original warrant. Ventresca, 380 U.S. at 107; Locke v. United States, 11 U.S. (7 Cranch) 339, 348 (1813). Geofence warrants further remove barriers by allowing law enforcement to outsource much of its investigative work, including finding a suspect, to private companies. See Maryland v. Garrison, 480 U.S. 79, 85 (1987). See Stanford, 379 U.S. at 482. Their increasingly common use means that anyone whose commute takes them goes by the scene of a crime might suddenly become vulnerable to suspicion, surveillance, and harassment by police. In the meantime, as law enforcement relies on the warrants, countless more passersby will become collateral damage., 2023 Cond Nast. With permission from a judge, they allow law enforcement to obtain anonymized data from Google from almost any device that was in a certain geographic . Few are as fortunate as McCoy, who at least was informed and had the opportunity to block the request in court. Spinelli v. United States, 393 U.S. 410, 419 (1969); see also United States v. Leon, 468 U.S. 897, 914 (1984); Illinois v. Gates, 462 U.S. 213, 236 (1983); United States v. Allen, 625 F.3d 830, 840 (5th Cir. In other words, officer discretion must be cabined not fully eliminated. After spending several thousand dollars retaining a lawyer, McCoy successfully blocked the release.44. Take a reasonably probable hypothetical: In response to the largest set of geofence warrants revealed to date, Google provided law enforcement with the location for 1,494 devices. See Arson, 2020 WL 6343084, at *10; Pharma II, 2020 WL 4931052, at *1617; Pharma I, 2020 WL 5491763, at *6. If they are not unconstitutional general warrants because the searched location data is confined to a particular space and time, courts should evaluate whether a warrant is supported by probable cause with respect to that area. The amount of behind-the-scenes cooperation between Apple-Facebook-Google-et-al and law enforcement would boggle the . It is unclear whether the data collected is stored indefinitely, see Webster, supra note 5 (suggesting that it is), but there are strong constitutional arguments that it should not be, see United States v. Ganias, 824 F.3d 199, 21518 (2d Cir. Part II begins with the threshold question of when a geofence search occurs and argues that it is when private companies parse through their entire location history databases to find accounts that fit within a warrants parameters. . Geofence warrants are amongst the many new ways policing has . WIRED may earn a portion of sales from products that are purchased through our site as part of our Affiliate Partnerships with retailers. and cases122122. how can probable cause to search a store located in a seventy-story skyscraper possibly extend to all the other places in the building? 2016); 1 Wayne R. LaFave, Search and Seizure: A Treatise on the Fourth Amendment 2.7(b), at 95355 (5th ed. at *7. See, e.g., Affidavit for Search Warrant, supra note 65, at 23. Here's another rejection covered by Techdirt this one arriving nearly a year ago . and with geofence warrants, there is often barely a law enforcement rationale. Few offer information regarding the scope of the geographical area to be searched in a unit of measurement most people would understand, like blocks or street parameters. Apple told the Times that it doesn't have the ability to furnish law enforcement with data in the same way as Google. It turns out that these warrants are so invasive of user privacy that big tech companies like Google, Microsoft, and Yahoo are willing to support banning them. If law enforcement needed to establish only probable cause to search a private companys location history records, probable cause would always be satisfied with the same choice statistics121121. See Carpenter v. United States, 138 S. Ct. 2206, 2212 (2018) (Wireless carriers collect and store CSLI for their own business purposes. Thomas Brewster, Feds Order Google to Hand Over a Load of Innocent Americans Locations, Forbes (Oct. 23, 2018, 9:00 AM), https://www.forbes.com/sites/thomasbrewster/2018/10/23/feds-are-ordering-google-to-hand-over-a-load-of-innocent-peoples-locations [https://perma.cc/EH8L-59ZU]. Snapchat and Apple, too. Elm, supra note 27, at 13; see also 18 U.S.C. In the past, the greatest protections of privacy were neither constitutional nor statutory, but practical.176176. The Court has recognized that when these rights are at issue, the warrant requirements must be accorded the most scrupulous exactitude. Stanford v. Texas, 379 U.S. 476, 485 (1965); see id. In re Search Warrant Application for Geofence Location Data Stored at Google Concerning an Arson Investigation (Arson)150150. All rights reserved. McCoy received notice from Google that he had seven days to go to court or risk the release of information related to his Google account and use of Google products to law enforcement.33. On the Android, it's simply called "Location". Geofence Warrants On The Rise. Cops have discovered Google houses plenty of location data. xKGr) ]c .`;#JV~GfF"F6xfedmBF{-ym7i}g/b}hjnWow8Y"av4J?wm_5_/xq Rather than waiting for challenges to geofence warrants to percolate and make their way up the court system,180180. Recently, users filed a class action against Google on these grounds. Rather than issuing a warrant for data on a specific individual, these warrants seek information on all of the devices in a given area at a given time. But they can do even more than support legislation in one state. See Berger v. New York, 388 U.S. 41, 5153 (1967). See 28 U.S.C. First, the narrowness of the anonymized list is largely in the hands of private companies, rather than the judiciary or legislature, which is impracticable in the long run. See, e.g., Albert Fox Cahn, Manhattan DA Made Google Give Up Information on Everyone in Area as They Hunted for Antifa, Daily Beast (Aug. 15, 2019, 4:35 PM), https://www.thedailybeast.com/manhattan-da-cy-vance-made-google-give-up-info-on-everyone-in-area-in-hunt-for-antifa-after-proud-boys-fight [https://perma.cc/5BKP-EFJD]; Lamb, supra note 5. 561 (2009). The Reverse Location Search Prohibition Act, A. The Things Seized. Id. Id. They also vary in the evidence that they request. Google Amicus Brief, supra note 11, at 13. Some have suggested that geofence warrants should be treated like wiretaps. Representative Kelly Armstrong suggested that geofence warrants should be considered contents within the Electronic Communications Privacy Act of 1986 (ECPA), Pub. Geofence warrants, which compel Google to provide a list of devices whose location histories indicate they were near a crime scene, are used thousands of times a year by American law enforcement . . July 14, 2020). To perform this function, the geofencing app accesses the real-time location data sent by the tracked device. Id. Companies can still resist complying with geofence warrants across the country, be much more transparent about the geofence warrants it receives, provide all affected users with notice, and give users meaningful choice and control over their private data. Tex. 20 M 297, 2020 WL 5491763, at *6 (N.D. Ill. July 8, 2020) (rejecting the governments argument that Googles framework curtail[s] or define[s] the agents discretion in a[] meaningful way); see also Arson, 2020 WL 6343084, at *10; Pharma II, No. In collaboration with The Nib and illustrator Chelsea Saunders, we've adapted "Coded Resistance" into comic form. Fifth Circuit Delivers a New Law Enforcement Functions Test for Identifying Government Actors. 2 (Big Hit Ent. U.S. Const. Through the use of geofence warrants (also known as reverse location warrants), federal and state law enforcement officers are routinely requesting that Google search users' accounts to determine who was in a certain geographic area at a particular timeand then to track individuals outside of that initially specific area and time period. See id. See Illinois v. Gates, 462 U.S. 213, 238 (1983). New iMac With 'iPad Pro Design Language'. But geofence warrants take it a step farther, looking for suspects in the absence of leads, casting a wide net without clues, and pursuing a person they don't already suspect. Geofence warrant requests in Virginia grew from 72 in 2018 to 484 in 2020, . In other words, the characterization of a geofence warrant as a search in the first place likely relies in part on the prevalence of cell phones. Brewster, supra note 82. Search Warrant, supra note 5. Wisconsin,2121. Id. In 2019, a single warrant in connection with an arson resulted in nearly 1,500 device identifiers being sent to the Bureau of Alcohol, Tobacco, Firearms, and Explosives. 1181 (2016). When a geofence warrant is executed, courts should recognize that the search consists of two components: a search through (1) a private companys database for (2) data associated with a particular time and place. Googles actions in all three parts of its framework are thus conducted in response to legal compulsion and with the participation or knowledge of [a] governmental official.8080. Google and other private companies act[] as. The court also highlighted the length of time (fifteen to thirty minutes170170. Support A.B. 20-cv-4688 (N.D. Cal. A general warrant is simply an egregious example of a warrant that is too broad in relation to the object of the search and the places in which there is probable cause to believe that it may be found.128128. In 2018, Google received 982 geofence warrants from law enforcement; in 2020 that number surged to 11,554, according to the most recent data provided by the company. Geofence warrants work differently from typical search warrants. does anyone know what happend to this or how i could do it? The Reverse Location Search Prohibition Act, / S. 296, would prohibit government use of geofence warrants and reverse warrants, a bill that EFF also, . With geofence warrants, police start with the time and location that a suspected crime took place, then request data from Google for the devices surrounding that location at that time, usually within a one- to two-hour window. Yet the scope of a geofence search is larger than almost any physical search. Mar. A warrant that authorized one limited intrusion rather than a series or a continuous surveillance thus could not be used as a passkey to further search.8787. . the Court found no probable cause to search thirty blocks to identify a single laundromat where heroin was probably being sold.116116. Pharma II, 2020 WL 4931052, at *16; see also Groh, 540 U.S. at 557. Safford Unified Sch. at *5 n.6. The breakthroughs and innovations that we uncover lead to new ways of thinking, new connections, and new industries. Companies can still resist complying with geofence warrants across the country, be much more transparent about the geofence warrants it receives, provide all affected users with notice, and give users meaningful choice and control over their private data. It means that an idle Google search for an address that corresponds to the scene of a robbery could make you a suspect. A geo-fence warrant (also known as a geofence warrant or a reverse location warrant) is a search warrant issued by a court to allow law enforcement to search a database to find all active mobile devices within a particular geo-fence area. I believe that iPhones that have Google apps like Gmail or Youtube running in the foreground have the capability to report location to Google. Yet Google often responds despite not being required to by a court.7575. L.J. It turns out that these warrants are so invasive of user privacy that big tech companies like Google, Microsoft, and Yahoo are willing to support banning them. Its closest competitor is Waze, which is also owned by Google. Just., Summer 2020, at 7. But they can do even more than support legislation in one state. Webster, supra note 5. In California, geofence warrant requests leaped from 209 in 2018 to more than 1,900 two years later. As consumers turn over ever-increasing information to third parties as part of engaging in daily life, there have been vigorous criticisms of the doctrine as out of touch with the modern era and calls to amend it or even abolish it entirely. See, e.g., Berger, 388 U.S. at 51 (suggesting that section 605 of the Communications Act of 1934, 47 U.S.C. Similarly, with a keyword warrant, police compel the company to hand over the identities of anyone who may have searched for a specific term, such as a victims name or a particular address where a crime has occurred. Raleigh Police Searched Google Accounts as Part of Downtown Fire Probe, WRAL.com (July 13, 2018, 2:07 PM), https://www.wral.com/scene-of-a-crime-raleigh-police-search-google-accounts-as-part-of-downtown-fire-probe/17340984 [https://perma.cc/8KDX-TCU5] (explaining that Google could not disclose its search for ninety days); Tony Webster, How Did the Police Know You Were Near a Crime Scene? << /Filter /FlateDecode /Length 4987 >> See, e.g., How Google Handles Government Requests for User Information, Google, https://policies.google.com/terms/information-requests [https://perma.cc/HCW3-UKLX]. Geofence warrants enable the government to conduct sweeping searches of cell phone location data for any phone that enters a predefined geographical boundary, or geofence, during limited time frames.2 The rising See id. Regarding Accounts Associated with Certain Location & Date Info., Maintained on Comput. There is, additionally, the age-old critique that judges do not understand the technologies they confront. Just this week, Forbes revealed that Google granted police in Kenosha, Wisconsin, access to user data from bystanders who were near a library and a museum that was set on fire last August, during the protests that followed the murder of George Floyd. Much has been said about how courts will extend Carpenter if at all.3939. Stored at Premises Controlled by Google (Pharma II), No. Law enforcement gets a warrant from a judge, then serves it to Google or Apple. The government must thus establish probable cause for the time146146. The three tech giants have issued a. ,'' that they will support a bill before the New York State legislature. Second, law enforcement reviews the anonymized list and identifies devices it is interested in.7171. In Wong Sun v. United States,115115. Use of this site constitutes acceptance of our User Agreement and Privacy Policy and Cookie Statement and Your California Privacy Rights. it is reasonable to believe that the perpetrators phone data can be found in these records. The warrant was thus sufficiently particular. The Court has recognized that the reasonableness standard introduces uncertainty, see United States v. Leon, 468 U.S. 897, 914 (1984), and many have criticized the standards flexibility and have called for its further definition, see, e.g., United States v. Ventresca, 380 U.S. 102, 117 (1965) (Douglas, J., dissenting); Ronald J. Bacigal, Making the Right Gamble: The Odds on Probable Cause, 74 Miss. Google provides the more specific informationlike an email address or the name of the account holderfor the users on the narrower list. See Google Amicus Brief, supra note 11, at 14. Id. Carpenter v. United States, 138 S. Ct. 2206, 221718 (2018); Riley v. California, 573 U.S. 373, 38586 (2014); see, e.g., Arson, No. But to the extent that law enforcement has discretion, that leeway exists only after it is provided with a narrowed list of accounts step two in Googles framework. While there was likely probable cause to search the businesses where pharmaceuticals were stolen, this probable cause did not extend to other units of the building or neighboring areas.153153. A single geofence request could include data from hundreds of bystanders. On the one hand, individuals have a right to be protected against rash and unreasonable interferences with privacy and from unfounded charges of crime.131131. During the protests in response to the murder of George Floyd, for example, companies collected and sold protesters phone data to political groups for election-related use,107107. In 2020, a warrant for users who had searched [for the victims address] close in time to the arson was granted, and Google responded by providing IP addresses of responsive users.185185. Texas,1818. The key to writing Chatrie compliant geofence warrants is a narrow scope and particularized probable cause. In Pharma I, the requested geofence spanned a 100-meter radius area within a densely populated city during several times in the early afternoon, capturing a large number of individuals visiting all sorts of amenities associated with upscale urban living.152152. See Skinner v. Ry. Redding, 557 U.S. at 370; see also Harris, 568 U.S. at 243; Ornelas v. United States, 517 U.S. 690, 696 (1996); Brown, 460 U.S. at 742 (plurality opinion); Brinegar, 338 U.S. at 17576. See Arson, 2020 WL 6343084, at *8. 1241, 1245, 126076 (2010) (arguing that [t]he practice of conditioning warrants on how they are executed, id. Two warrants included just a commercial lot and high school event space, which was highly unlikely to be occupied.167167. 347, 37388. Particularity was constitutionalized in response to these reviled general warrants.9595. 20 M 525, 2020 WL 6343084, at *10 (N.D. Ill. Oct. 29, 2020); Pharma II, No. These reverse warrants have serious implications for civil liberties. See Products, Google, https://about.google/products [https://perma.cc/ZVM7-G9BX]. (May 31, 2020). Third, and finally, Google provides account-identifying information, such as the first names, last names, and email addresses of the users.7676. Lab. Law enforcement investigators have also made geofence requests to tech companies including Apple, Snapchat and Uber. many do not.7474. and geographic area delineated by the geofence warrant. 19, 2018), https://appleinsider.com/articles/18/03/19/police-are-casting-a-wide-net-into-the-deep-pool-of-google-user-location-data-to-solve-crimes [https://perma.cc/42VM-VUSD] (reporting that only one in four geofence warrants resulted in an arrest by the Raleigh Police Department). ; Fed. CSLI,9999. .); Google Amicus Brief, supra note 11, at 14 (To produce a particular users CSLI, a cellular provider must search its records only for information concerning that particular users mobile device.). Each one of these orders could sweep in hundreds or . The Washington Post recently published an op-ed by Megan McArdle titled "Twitter might be replaced, but not by Mastodon or other imitators." It ensures that the search will be carefully tailored to its justifications126126. People v. Weaver, 909 N.E.2d 1195, 1199 (N.Y. 2009), quoted in United States v. Jones, 565 U.S. 400, 415 (2012) (Sotomayor, J., concurring). or leverages the technology of a wireless carrier, we hold that an individual maintains a legitimate expectation of privacy in the record of his physical movements . 2019). See, e.g., Steele v. United States, 267 U.S. 498, 50405 (1925) (concluding, despite the fact that the cases of whiskey seized may not have been the exact cases that officials saw being delivered and that served as the basis of the warrant, that particularity was satisfied). Global Nav Open Menu Global Nav Close Menu Finds Contact Between Proud Boys Member and Trump Associate Before Riot, N.Y. Times (Mar. . Google uses its stored location data to personalize advertisements, estimate traffic times, report on how busy restaurants are, and more. If a geofence search involves looking through a private companys entire location history database step one in the Google context there are direct parallels between geofence warrants and general warrants. Sixty-seven percent of smartphone users who use navigation apps prefer Google Maps. Compare United States v. Ross, 456 U.S. 798, 821 (1982) ([A] warrant that authorizes an officer to search a home for illegal weapons also provides authority to open closets, chests, drawers, and containers in which the weapon might be found.), with Arson, 2020 WL 6343084, at *10 (When the court grants a warrant for a unit in [an] apartment building for evidence of a wire fraud offense, it does not grant a warrant for that entire floor or the entire apartment building, but rather the specific apartment unit where there is a fair probability that evidence will be located.). BTS, Baepsae, on The Most Beautiful Moment in Life Pt. 1 v. Redding, 557 U.S. 364, 371 (2009) (citations omitted) (quoting Gates, 462 U.S. at 238, 244 n.13); see also Texas v. Brown, 460 U.S. 730, 735 (1983) (plurality opinion). Geofence warrants represent both a continuation and an evolution of this relationship. The report shows that requests have spiked dramatically in the past three years, rising as much as tenfold in some states. Similarly, the Court has explained that the purpose of the particularity requirement is not limited to the prevention of general searches.125125. Between 2017 and 2018, Google saw a 1,500% increase in geofence requests. 531, 551 (2005) (emphasis added). Access to the storehouse by law enforcement continues to generate controversy because these warrants vacuum the location . S8183, 20192020 Leg. L. Rev. 2016) (en banc). from Android usersapproximately 131.2 million Americans4343. S. ODea, Number of Android Smartphone Users in the United States from 2014 to 2021, Statista (Mar. at 552. Just this week, Kenosha lawmakers debated a bill that would make attending a riot a felony. . 13, 2019), https://nyti.ms/2DnN7KT [https://perma.cc/P5N3-4HSD]. Even assuming that complying with a geofence warrant constitutes a search, there remains a difficult and open threshold question about when the search occurs. George Joseph & WNYC Staff, Manhattan DA Got Innocent Peoples Google Phone Data Through a Reverse Location Search Warrant, Gothamist (Aug. 13, 2019, 5:38 PM), https://gothamist.com/news/manhattan-da-got-innocent-peoples-google-phone-data-through-a-reverse-location-search-warrant [https://perma.cc/RH9K-4BJZ]. Geofencing itself simply means drawing a virtual border around a predefined geographical area. Individuals would have had to possess extremely keen eyesight and perhaps x-ray vision to have had any awareness of the crime at all.154154. 2518(1)(c). at 48081. A general warrant is one that specifie[s] only an offense, leaving to the discretion of executing officials the decision as to which persons should be arrested and which places should be searched.9191. Without additional warrants, officials are given leeway to expand searches beyond the time and geographic scope of the original request8383. Otherwise, privacy protections would be left largely to the discretion of law enforcement rather than the judiciary or legislature.8989. Id. New figures from Google show a tenfold increase in the requests from law enforcement, which target anyone who happened to be in a given location at a specified time. The warrant specifies a physical location and a time period. 388 U.S. 41 (1967). On the other hand, the government has an interest in finding incriminating evidence and preventing crime.132132. at 48081. Groh v. Ramirez, 540 U.S. 551, 561 (2004). For more applicable recommendations, see Rachel Levinson-Waldman, Brennan Ctr. Critics noted that such a bill could penalize anyone attending peaceful demonstrations that, because of someone elses actions, become violent. Last week, Google responded to calls by a civil liberties coalition, including POGO, to issue a report of how often it receives geofence demands. The Chatrie opinion suggests it would approve a geofence warrant process in which a magistrate or court got to make a probable cause determination before geofence data of the likely suspect is de . Additionally, geofence warrants are usually sealed by judges.5858. Second, this list is often quite broad. In practice, inquiry into probable cause for time will likely overlap with the preliminary question of whether geofence warrants are searches. 18 U.S.C. Courts and legislatures must do a better job of keeping up to ensure that privacy rights are not diminished as technology advancesregardless of how effective those capabilities might be at solving crimes.186186. 19-cr-00130 (E.D. Thomas Brewster, Google Hands Feds 1,500 Phone Locations in Unprecedented Geofence Search, Forbes (Dec. 11, 2019, 7:45 AM), https://www.forbes.com/sites/thomasbrewster/2019/12/11/google-gives-feds-1500-leads-to-arsonist-smartphones-in-unprecedented-geofence-search [https://perma.cc/PML8-W2UR]. Id. As . See id. Emblematic of general warrants, these warrants should be highly suspect per se. As a result, Molina dropped out of school, lost his job, car, and reputation, and still has nightmares about sitting alone in his jail cell.88. See United States v. Patrick, 842 F.3d 540, 54245 (7th Cir. Of the courts that have considered these warrants, most have implicitly treated the search as the point when the private company first provides law enforcement with the data requested step two in Googles framework with no explanation why.7777. id. Law enforcement simply specifies a location and period of time, and, after judicial approval, companies conduct sweeping searches of their location databases and provide a list of cell phones and affiliated users found at or near a specific area during a given timeframe, both defined by law enforcement.1111. Now, a group of researchers has learned to decode those coordinates. This Part describes the limited role judges and the public currently play in approving and scrutinizing geofence warrants and how Google responds to them. The Richmond police used personal data from Google Maps to crack a six-month-old bank robbery, triggering protests from the suspect's counsel that the use of what is known as a "geofence warrant . See Coolidge v. New Hampshire, 403 U.S. 443, 467 (1971) (explaining that particularity guarantees that intrusions are as limited as possible). The figures, published Thursday, reveal that Google has received thousands of geofence warrants each quarter since 2018, and at times accounted for about one-quarter of all U.S. warrants that . Congress must engage in proactive legislation as it has done with other technologies181181. Though admittedly an open question, Google has advocated that they are,2828. In Ohio, requests rose from seven to 400 in that same time. amend. It is, however, unclear how Google determines whether a request is overly broad. and has developed a [three]-step anonymization and narrowing protocol for when it does respond to them.6868.

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