the name of a requested file or article.”47 Though none of these authorities offer detailed reasoning on why they draw the “content” line where they do, what they have in common is that they assess whether a URL involves “contents” based on how much information would be revealed by disclosure of the URL. Third, the Surveillance Court’s example of post-cutthrough digits in the telephone context—i.e. numbers dialed from a telephone after a call is already setup or “cutthrough”—hints at a different reason why queried URLs might be considered content. A number of courts apart from the Surveillance Court—most prominently the D.C. Circuit— have found such digits to comprise communications content beyond the permissible scope of a pen register.48 URL queries 47 See H. Rep. No. 107-36, at 53. 48 See U.S. Telecom Ass’n v. F.C.C., 227 F.3d 450, 462 (D.C. Cir. 2000) (“Post-cut-through dialed digits can . . . represent call content. For example, subjects calling automated banking services enter account numbers. When calling voicemail systems, they enter passwords. When calling pagers, they dial digits that convey actual messages. And when calling pharmacies to renew prescriptions, they enter prescription numbers.”); In re Applications of the U.S., 515 F. Supp. 2d 325, 339 (E.D.N.Y. 2007) (“[T]he “Government’s request for access to all post-cut-through dialed digits is not clearly authorized by the Pen/Trap Statute, and . . . granting such a request would violate the Fourth Amendment . . . .”); In re Application of the U.S., 441 F. Supp. 2d at 827 (“Post-cutthrough dialed digits . . . are not available to law enforcement under the Pen/Trap Statute.”). 25