Surveillance Court read this to mean that, for purposes of federal surveillance law, information may well serve both a routing function and a content function. Noting the breadth of the statutory descriptions of routing information and “content,” the Surveillance Court concluded that routing information and “content” are not mutually exclusive categories, but rather ones that Congress expressly contemplated to be occasionally coextensive.40 Proceeding to identify exemplary areas where routing information and “content” overlap, the Surveillance Court pointed, “in particular,” to URL queries that involve reproduction of a search phrase entered by a user into a search engine.41 Quoting the District of Massachusetts, the Surveillance Court explained that, “if a user runs a search using an [i]nternet search engine, the ‘search phrase would appear in the URL after the first forward slash’ as part of the addressing information, but would also reveal contents, i.e., the ‘“substance” and “meaning” of the communication . . . that the user is conducting a search for information on a particular topic.’”42 For an example from another context, the court pointed to post-cut-through digits in the phone context “as 40 Id. at 31. 41 Id. at 32. 42 Id. at 32 (final alteration in original) (quoting In re Application of the U.S., 396 F. Supp. 2d 45, 49 (D. Mass. 2005)). 22

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