42 UNITED STATES V. MOHAMUD increase the importance of minimization procedures once the communications are collected.24 Additionally, Mohamud and Amici contend that prior cases upholding incidental collection involved prior judicial review or a “narrowly drawn exception to the warrant requirement,” as opposed to the collection here. See, e.g., United States v. Kahn, 415 U.S. 143, 156–57 (1974) (upholding interception of communications of a woman that were incidentally collected under a wiretap order targeting her husband); United States v. Figueroa, 757 F.2d 466, 473–75 (2d Cir. 1985) (holding that wiretap order was not made unconstitutional by permitting interception of conversations of “others as yet unknown”); see also United States v. Martin, 599 F.2d 880, 884–85 (9th Cir. 1979) (holding that the Fourth Amendment does not require wiretap application to show probable cause that non-targeted individual named as a “probable converser” committed a crime), overruled on other grounds by United States v. De Bright, 730 F.2d 1255 (9th Cir. 1984) (en banc). However, the searches in those cases targeted United States citizens and took place within the United States, so a warrant was required for the initial search to be constitutionally permissible. But “the guiding principle behind them applies with equal force here: when surveillance is lawful in the first place—whether it is the domestic surveillance of U.S. persons pursuant to a warrant, or the warrantless surveillance of non-U.S. persons who are abroad—the incidental interception of non-targeted U.S. persons’ communications with the targeted persons is also lawful.” Hasbajrami, 2016 WL 1029500, at *9. 24 To the extent that Amici argue that the incidental overhear doctrine permits the unconstitutional and widespread retention and querying of the incidentally collected information, that issue is not before us.