BAGELY_FORMAT_PT 1/27/2011 2:01 PM
156 ALB. L.J. SCI. & TECH. [Vol. 21.1
parties such as information service provider, Google, and
telecommunication giant, AT&T, amass large amounts of
personal user data.
9
In many instances, citizens relinquish
personal data in exchange for free services, such as email and
instant messaging, or low-cost long distance phone calls.
10
Traditionally, such data has been used by companies for niche
marketing and research purposes.
11
However, in recent years the
United States government has built national security databases
with personal user data allegedly obtained from cooperating
telecommunication companies such as Bellsouth,
12
AT&T
13
and
Verizon.
14
In 2006, lawsuits against Bellsouth, AT&T and Verizon alleged
that the companies violated consumer confidentiality by
/sample_bills/sample_print_lld.html (last visited Nov. 29, 2010) (AT&T provides
phone services for a fee); Welcome to Gmail, G
MAIL, http://mail.google.com/mail/
help/open.html (last visited Nov. 29, 2010) (Google provides email service for
free). An enormous population is transmitting their personal data through
computer servers owned by private parties. See Solarina Ho, Poll Finds Nearly
80 Percent of U.S. Adults Go Online, R
EUTERS (Nov. 5, 2007, 8:35 PM),
http://www.reuters.com/article/internetNews/idUSN0559828420071106?feedTy
pe=RSS&feedName=internetNews&rpc=22&sp=true (nearly 80% of American
adults use the Internet).
9
See Elinor Mills, Google Balances Privacy, Reach, CNET NEWS (July 14,
2005, 4:00 AM), http://news.cnet.com/Google-balances-privacy,-reach/2100-
1032_3-5787483.html; Eric Benderoff & Jon Van, Privacy? What Privacy?, C
HI.
T
RIB., May 14, 2006, http://articles.chicagotribune.com/2006-05-14/news/0605
140367_1_google-privacy-digital.
10
See Robert Luke, Web Portals as Purchasing Ideology, 8 TOPIA: CAN. J. OF
C
ULTURAL STUD. 61, 61, 64, 70–71, 71 n.11 ( 2002), available at
http://pi.library.yorku.ca/ojs/index.php/topia/article/viewFile/142/133
(explaining that to use ISP services such as email and instant messaging
“clients must relinquish their personal data”); Teach Your Phone New Tricks,
G
OOGLE VOICE, https://www.google.com/accounts/ServiceLogin?service=
grandcentral&passive=1209600&continue=https://www.google.com/voice&follow
up=https://www.google.com/voice<mpl=open (last visited Nov. 29, 2010)
(showing that by creating a Google account, users can access Google Voice
which provides free calls to the U.S. and Canada and provides “[s]uper low rates
everywhere else”).
11
Simon Lazarus & Brett Kappel, Europeans Spur U.S. Debate: Protecting
Privacy From Prying Eyes, LEGAL TIMES, June 15, 1998.
12
Cheryl Bronson & Pam Benson, BellSouth, AT&T Added to NSA Lawsuit,
CNN.
COM (May 17, 2006), http://edition.cnn.com/2006/POLITICS/0
5/16/NSA.suit/.
13
Leslie Cauley, NSA Has Massive Database of Americans’ Phone Calls, USA
TODAY, May 11, 2006, http://www.usatoday.com/news/washington/2006-05-10-
nsa_x.htm.
14
Marguerite Reardon, Verizon Sued for Alleged NSA Cooperation, CNET
N
EWS (May 15, 2006, 3:16 PM), http://news.cnet.com/Verizon-sued-for-alleged-
NSA-cooperation/2100-1036_3-6072483.html.