1. criticizing Clapper v. Amnesty Int'l USA, 133 S. Ct. 1138 (2013) (holding that plaintiffs "cannot manufacture standing merely by inflicting harm on themselves based on their fears of hypothetical future harm that is not certainly impending"); see also Wikimedia Foundation v;See Sudha Setty;Surveillance, Secrecy and the Search for Meaningful Accountability,2015
2. The Unterritoriality of Data, 125 YALE L;E G See;discussing United States v. Verdugo-Urquidez, 494,1990