In United States v. Forrester, meanwhile, a different panel of the Ninth Circuit noted that warrantless capture of URLs generally “might be more constitutionally problematic” than warrantless capture of IP addresses.45 The Forrester court explained that “[a] URL, unlike an IP address, identifies the particular document within a website that a person views and thus reveals much more information about the person’s [i]nternet activity.”46 Akin to Forrester is the stance taken by the House Judiciary Committee in its PATRIOT Act report, which stated that a pen register order “could not be used to collect information other than ‘dialing, routing, addressing, and signaling’ information, such as the portion of a URL (Uniform Resource Locator) specifying Web search terms or constitute a communication such that divulging a URL containing that search term to a third party could amount to disclosure of the contents of a communication. But the referrer header information at issue here includes only basic identification and address information, not a search term or similar communication made by the user, and therefore does not constitute the contents of a communication.”). 45 512 F.3d 500, 510 n.6 (9th Cir. 2008). An “IP address” is “[t]he 10-digit identification tag used by computers to locate specific websites.” Black’s Law Dictionary (10th ed. 2014) (“Internet-protocol address”). 46 512 F.3d at 510 n.6; see also Tokson, The Content/Envelope Distinction in Internet Law, 50 Wm. & Mary L. Rev. at 2136 (“[S]tandard URLs . . . reveal every bit as much content as do URLs containing search terms.”). 24