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230 NOTES
190. Gellman and Soltani, “NSA Collects Millions of e-mail Address Books Globally.”
191. Glenn Greenwald, “XKeyscore: NSA Tool Collects ‘Nearly Everything a User
Does on the Internet,’ ” The Guardian, July 31, 2013; see also Barton Gellman
et al., “In NSA-intercepted Data, Those Not Targeted Far Outnumber the For-
eigners Who Are,” Washington Post, July 5, 2014.
192. Hendrik Hertzberg, “Snoop Scoops,” The New Yorker, June 24, 2013, http://
www.newyorker.com/talk/comment/2013/06/24/130624taco_talk_hertz-
berg; for the opposing view, see Katherine Strandburg, “Membership Lists,
Metadata, and Freedom of Association’s Specificity Requirement,” ISJLP 10:
327 (“relational surveillance using so-called metadata implicates the First
Amendment right to freedom of association,” which “imposes specificity
requirements on government acquisition of associational information that
are not met by the NSA’s comprehensive and undifferentiated collection and
scrutiny of associational information.” )
193. Luke Johnson, “Obama Defends NSA Programs, Says Congress Knew About
Surveillance,” The Huffington Post, June 7, 2013, http://www.huffingtonpost.
com/2013/06/07/obama-nsa_n_3403389.html.
194. Ellen Nakashima, “NSA Gathered Thousands of Americans e-mails before
Court Ordered It to Revise Its Tactics.”
195. Trevor Timm, “President Obama claims the NSA has Never Abused Its
Authority. That’s False,” The Guardian, December 31, 2013.
196. Chris Strohm, “Lawmakers Probe Willful Abuses of Power by NSA Analysts,”
Bloomberg, August 24, 2013.
197. Siobhan Gorman, “NSA Officers Spy on Love Interests,” Wall Street Journal,
August 23, 2013.
198. Kyle Balluck, “Former CIA Official Admits to ‘Very Minor’ NSA Abuses,” The
Hill, January 19, 2014.
199. Barton Gellman, “NSA Broke Privacy Rules Thousands of Times per Year,
Audit Finds,” Washington Post, August 15, 2013.
200. Carol D. Leonnig, “Court: Ability to Police U.S. Spying Program Limited,”
Washington Post, August 15, 2013.
201. Ibid.
202. John D. Bates, “April 2011 Submissions,” as published in The Washington Post,
http://apps.washingtonpost.com/g/page/national/fisa-court-documents-on-
illegal-nsa-e-mail-collection-program/409/ p. 16, note 14.
203. Scott Shane, “Court Upbraided N.S.A. on Its Use of Call-Log Data,” New York
Times, September 10, 2013, http://www.nytimes.com/2013/09/11/us/court-
upbraided-nsa-on-its-use-of-call-log-data.html?pagewanted=all.
204. Ibid.
205. Eyder Peralta, “Senators Announce Bill That Ends NSA Phone Records
Collection,” NPR, September 25, 2013, http://www.npr.org/blogs/
thetwo-way/2013/09/25/226263270/senators-announce-bill-that-ends-
nsa-phone-records-collection.
206. Such demands came not only from rights advocates such as the American
Civil Liberties Union (see, for example, ACLU, “Bringing Transparency to the