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The contrasting formulations were posited as useful analogies in Doe v. United States, 487 U.S. In Doe, the signing of a blank bank consent form was considered more like the production of a physical object. By contrast in Hubbell v. United States, 530 U.S. 27 (2000), the documents produced by the defendant in response to a subpoena were organized and selected through his own mental analysis and thus protected from disclosure.

Few court cases have addressed the encryption question directly: Two, United States v. Rogozin, 2010 WL 4628520 (W.D.N.Y.

Marigor Und Die Tobis Clothing. 2010) and United States v. Kirschner, 2010 WL 1257355 (E.D. March 30, 2010) thought that the password could not be compelled, while another, In re Boucher, 2009 WL 424718, *1 (D. 2009), available at, was decided on the technicality that Boucher had already given the government access to his computer once, so he could not object to doing so a second time and disclosing his encryption key.

When the Clipper chip (a chip to allow decryption of encrypted phone traffic) was first introduced, flaws in it were quickly found. See Matt Blaze, Protocol Failure in the Escrowed Encryption Standard (Aug. 20, 1994), available at More recently, Greek official communications were intercepted illegally through a security flaw created by the inclusion of built-in interception feature. See Vodafone Greece Rogue Phone Taps: Details at Last, H Security, available at http://www.h-online.com/security/news/item/Vodafone-Greece-rogue-phone-taps-details-at-last-733244.html.

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