although it is true that some Complainants’ complaints were filed one year after the date of the act of acquisition of communications data, where they were unaware of the fact that their communications data were submitted to the investigative agency et al. due to a lack of ex-post notification procedures, etc., the limitation period for filing should be judged based on whether 90 days have expired from the date of actual knowledge. 2. Arguments on Merits (a) Although the act of acquisition of communications data by the investigative agency et al. under the Act Provision constitutes a compulsory measure subject to the principle of warrant, the Act of Acquiring Communications Data by Respondents was carried out without a warrant. In addition, in the case of Complainants J.S. et al. listed in Appendix 3, the acts of acquisition of their communications data were performed without a reason specified by the Act Provision, and in particular, the investigative agency obtained the communications data of Complainant L.G. seven times. Respondents argue that they obtained the communications data to achieve the purpose of the investigation because there were records of phone conversations between Complainants and the suspect or person of interest, but they did not prove anything about whether the act of acquisition of communications data of Complainants was indispensable. Therefore, the Act of Acquiring Communications Data is in violation of the principle of warrant and the rule against excessive restriction and infringes on the right to informational self-determination of Complainants J.S. et al. listed in Appendix 3. (b) The act of acquisition of communications data pursuant to the Act Provision amounts to a compulsory measure as the investigative agency et al. conducted it in a superior position, and thus the Act Provision in effect permits search and seizure without a warrant. What’s more, the - 32 -