In September 2007, the Southern District Court of New York in Doe v. Gonzales, 500 F.Supp.2d 379 (S.D.N.Y.2007) declared subsections 2709(c) and 3511(b) of federal law unconstitutional for violations of the First Amendment right to free speech and the separation of powers principle. Subsection 2709(c) prohibits a wire or electronic communication service provider from disclosing to any person that it is a recipient of a National Security Letter (NSL) by the Federal Bureau of Investigation (FBI). NSL is a request for information about specified Internet subscribers. As amended by U.S. Congress, subsection 2709(c)'s non-disclosure requirement applies only when the government certifies that revealing the receipt of an NSL may result in: danger to national security, interference with an investigation, or danger to the life or physical safety of any person. Subsection 3511(b) provides the recipient the right to petition for judicial review of the NSL's nondisclosure requirement. The U.S. government appealed the district court's ruling to the Second Circuit U.S. Court of Appeals. The Court partially invalidated subsections 2709(c) and 3511(b). It ruled that the conclusive presumption clauses of subsection 3511(b) violated the First Amendment because to "accept deference to that extraordinary degree would be to reduce strict scrutiny to no scrutiny, save only in the rarest of situations where bad faith could be shown." It also declared subsections 2709(c) and 3511(b) unconstitutional" to the extent that they impose a nondisclosure requirement without placing on the [g]overnment the burden of initiating judicial review of that requirement."