Case 1:20-mc-00036-JEB-ZMF Document 22 Filed 09/22/21 Page 18 of 32 see HRIA 12–14. Moreover, by banning coordinated inauthentic behavior from Facebook nearly three years ago, Facebook has already deterred users with such content from entering its platform. See Coordinated Inauthentic Behavior, Facebook https://about.fb.com/news/tag/coordinated-inauthentic-behavior/. (Dec. Second, 6, the 2018), harm of “unauthorized users [] obtain[ing] access to communications to which they are not a party,” S. Rep. No. 99-541, at 5 (1986), is mitigated where the content is limited to unauthorized inauthentic accounts, as opposed to genuine communications from real users. Additionally, the Court and Facebook still serve as gatekeepers on releasing records to unauthorized users. Third, concerns about disclosure damaging the right to privacy, see id., is a boogeyman that does not haunt here. Coordinated inauthentic behavior—i.e., fake accounts that violated the terms of service—had no privacy rights from Facebook. And the right to privacy in this case must be balanced against the need to uncover the cause of the Rohingya genocide. d. Privacy Concerns Finally, Facebook advances a policy argument, opining that this Court’s holding will “have sweeping privacy implications—every time a service provider deactivates a user’s account for any reason, the contents of the user’s communications would become available for disclosure to anyone, including the U.S. government.” 11 Resp’t’s Surreply at 7. Facebook taking up the mantle of privacy rights is rich with irony. News sites have entire sections dedicated to Facebook’s sordid history of privacy scandals. See, e.g., 11 Facebook Privacy Scandal, AP News, Facebook’s argument that this holding is a boon to law enforcement misses the mark. Law enforcement already accesses content regularly via search warrants. The Fourth Amendment requirement for a search warrant is untouched by this Court’s reading of the SCA. The Fourth Amendment’s privacy protections stand apart from the SCA. See United States v. Warshak, 631 F.3d 266 (6th Cir. 2010). Indeed, the Fourth Amendment broadly protects digital media irrespective of SCA coverage. See, e.g., Riley v. California, 573 U.S. 373 (2014). 18