Filed an amicus brief (with other amici) in the U.S. Supreme Court in United States v. Microsoft Corp. The brief stresses that journalists must be able to protect sensitive reporting materials in the modern digital newsroom, which resides in the cloud. The brief notes that expanding the U.S. government’s ability to reach electronic records stored outside its borders sets a dangerous international example that foreign governments hostile toward journalists may exploit. The brief further notes that there is a meaningful distinction between warrants and subpoenas that must be maintained. This distinction has long been central to U.S. press protections, functioning as a restraint on government power.