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FISA Court,” 2013, https://www.aclu.org/bringing-transparency-fisa-court),
but also from affected tech firms (see, for example, Alanna Petroff, “Marissa
Mayer Calls for More NSA Transparency,” CNN Money, January 22 2014)
and academia (see, for example, Bryce Clayton Newell, “The Massive Meta-
data Machine: Liberty, Power, and Secret Mass Surveillance in the U.S. and
Europe,” ISJLP 10: 481).
207. Peter Baker, “After Leaks, Obama Leads Damage Control Effort,” The New
York Times, June 28, 2013, http://www.nytimes.com/2013/06/29/us/politics/
after-leaks-obama-leads-damage-control-effort.html?pagewanted=all.
208. Trevor Timm, “The NSA Leaks Are Forcing More Transparency on
Both Companies and the Government,” Freedom of the Press Founda-
tion, June 15, 2013, https://pressfreedomfoundation.org/blog/2013/06/
nsa-leaks-are-forcing-more-transparency-both-companies-and-government.
209. Ellen Nakashima, “Bipartisan Group of Senators Urges Transparency on
Phone Record Surveillance,” The Washington Post, June 28, 2013, http://
articles.washingtonpost.com/2013-06-28/world/40251889_1_phone-
records-bulk-collection-senators.
210. Scott Shane, “U.S. is Urged to Consider Releasing Data on Calls,” The New
York Times, September 14, 2013, A10.
211. Ibid.
212. Scott Shane, “New Leaked Document Outlines U.S. Spending on Intelli-
gence Agencies,” The New York Times, August 29, 2013, http://www.nytimes.
com/2013/08/30/us/politics/leaked-document-outlines-us-spending-on-
intelligence.html?pagewanted=all.
213. Intelligence official reports that a leak to the press regarding the government’s
capability to intercept al Qaeda’s electronic communications prompted the
group to immediately and dramatically change the way in which they com-
municated and the sorts of information that passed through electronic chan-
nels to avoid U.S. surveillance. See, Eric Schmitt and Michael S. Schmidt,
“Qaeda Plot Leak has Undermined U.S. Intelligence.”
214. Scott Shane and David E. Sanger, “Job Title Key to Inner Access Held
by Snowden,” The New York Times, June 30, 2013, http://www.nytimes.
com/2013/07/01/us/job-title-key-to-inner-access-held-by-snowden.
html?pagewanted=all.
215. Vindu Goel and Claire Cain Miller, “More Data on Privacy, but Picture
Is No Clearer,” The New York Times, June 17, 2013, http://www.nytimes.
com/2013/06/18/technology/more-data-on-privacy-but-picture-is-no-
clearer.html.
216. Spencer Ackerman, “Senators Press NSA Director for Answers on Secret Sur-
veillance Program,” The Guardian, June 12, 2013, http://www.guardian.co.uk/
world/2013/jun/12/senate-nsa-director-keith-alexander.
217. Andrea Peterson and Scott Wilson, “Former U.S. Officials to Assess Surveil-
lance Policy,” The Washington Post, August 23, 2013, A2.
Such a board might also take the form of something along the lines of the
Privacy and Civil Liberties Oversight Board. See Garrett Hatch, “Privacy and