Case 2:16-mj-01061-TJR Document 13 Filed 02/03/17 Page 21 of 29 Id. at 323-24. The Supreme Court found that copying the serial numbers did not constitute a "seizure" under the Fourth Amendment. The Court explained: We agree that the mere recording of the serial numbers did not constitute a seizure. To be sure, that was the first step in a process by which respondent was eventually deprived of the stereo equipment. In and of itself, however, it did not "meaningfully interfere" with respondent's possessory interest in either the serial numbers or the equipment, and therefore did not amount to a seizure. Id. at 324. Following Hicks, the Third Circuit has held that a police officer's movement of documents from one place to another so that the documents could be reviewed by another law enforcement officer did not constitute a seizure. United States v. Menon, 24 F.3d 550, 559-60 (3d Cir. 1994) (Becker, J). The court reasoned that the police officer did not seize the documents at issue when she carried the documents from one office to an adjacent office because such movement did not meaningfully interfere with the possessory interest of the individual from whose office the documents were taken. Id. at 560. Other circuit courts have held that photocopying documents or taking photographs of materials did not constitute a "seizure" because such actions did not meaningfully interfere with the owners' possessory interest. See United States v. Mancari, 463 F.3d 590, 596 (7th Cir. 2006) (photographs); Bills v. Aseltine, 958 F.2d 697, 707 (6th Cir. 1992) (photographs); United States v. Thomas, 613 F.2d 787, 794 (10th Cir. 1980) (photocopies). It is not surprising, therefore, that two district courts have held that accessing electronic data is not a "seizure." See In re United States, 665 F.Supp. 2d 1210, 1222 (D. Or. 2009) (court found no "seizure" because there was no "meaningful interference due to the nature of electronic information, which can be accessed from multiple locations, by multiple people, simultaneously."); United States v. Gorshkov, 2001 WL 1024026, at *4 (W.D. Wash. May 23, 2001) (FBI agent's act of copying 21