“These are the only two public affidavits uncovered so far, but it’s entirely possible that more have been filed under seal. Business records of this kind are also frequent targets for national security requests, a gag-ordered subpoena that some judges have criticized as unconstitutional. The company’s most recent transparency report lists just over 12,000 US government requests in the first half of 2015, 78 percent of which produced some user data, although the majority of those requests are typically for Gmail inbox content. The company does not break out location requests individually.”
http://www.theverge.com/2016/6/1/11824118/google-android-location-data-police-warrants
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