It would be foolish to contend that the degree of privacy secured to citizens by the Fourth Jointly reviewed and edited by YALE JOURNAL OF LAW & TECHNOLOGY and INTERNATIONAL JOURNAL OF COMMUNICATIONS LAW & POLICY. ∗ B.A. with high distinction, University of Virginia, M.T., University of Virginia, J.D. expected, Georgetown University Law Center. I would especially like to thank Scott Eltringham for his invaluable suggestions, which led to the creation of this piece, as well as his comments and insight throughout its development. I also wish to thank Kristy Bernard, Kelsi Brown Corkran, Robert A. Kaplan, Elizabeth Kennett, Jeffrey Shulman and Michael Songer for their suggestions and edits, all of which were important and very much appreciated.