Case 4:16-cr-40070-KES Document 262 Filed 02/17/17 Page 7 of 11 PageID #: 899 government, law enforcement agencies can permanently save all unresponsive data collected from a cell phone after a search for future prosecutions on unrelated charges. If the government’s argument is taken to its natural conclusion, then this opens the door to pretextual searches of a person’s cell phone for evidence of other crimes. Under the government’s view, law enforcement officers could get a warrant to search an individual’s cell phone for minor infractions and then use the data to prosecute felony crimes. No limit would be placed on the government’s use or retention of unresponsive cell phone data collected under a valid warrant. As the Supreme Court noted in Riley, cell phone data can include immense amounts of information such as “thousands of photos,” months of correspondence, or “every bank statement from the last five years.” Id. at 2493. The search of a cell phone can provide far more information than the most exhaustive search of a house. Id. at 2491. This is especially true because cell phones collect many different kinds of data in one place such as “an address, a note, a prescription, a bank statement, a video . . . .” Id. at 2489. “The sum of an individual’s private life can be reconstructed through a thousand photographs labeled with dates, locations, and descriptions . . . .” Id. The government’s position, which would allow for mass retention of unresponsive cell phone data, is simply inconsistent with the protections of the Fourth Amendment. The government’s objection on this point is overruled. 7