Facebook has willingly provided information in response to government subpoenas or requests, except with regard to private, unopened inbox messages less than 181 days old, which would require a warrant and a finding of probable cause under federal law under Electronic Communications Privacy Act (ECPA). One 2011 article noted that "even when the government lacks reasonable suspicion of criminal activity and the user opts for the strictest privacy controls, Facebook users still cannot expect federal law to stop their 'private' content and communications from being used against them". Facebook's privacy policy states that "We may also share information when we have a good faith belief it is necessary to prevent fraud or other illegal activity, to prevent imminent bodily harm, or to protect ourselves and you from people violating our Statement of Rights and Responsibilities. This may include sharing information with other companies, lawyers, courts or other government entities". Since the U.S. Congress has failed to meaningfully amend the ECPA to protect most communications on social-networking sites such as Facebook, and since the U.S. Supreme Court has largely refused to recognize a Fourth Amendment privacy right to information shared with a third party, no federal statutory or constitutional right prevents the government from issuing requests that amount to fishing expeditions and there is no Facebook privacy policy that forbids the company from handing over private user information that suggests any illegal activity. The 2013 mass surveillance disclosures identified Facebook as a participant in the U.S. National Security Administration's PRISM program. Facebook now reports the number of requests it receives for user information from governments around the world. In 2022, Nesbraska police charged a teenage girl and her mother after obtaining Facebook messages which allegedly showed that they performed an illegal self-managed medication abortion. Complaint from CIPPIC On May 31, 2008, the Canadian Internet Policy and Public Interest Clinic (CIPPIC), per Director Phillipa Lawson, filed a 35-page complaint with the Office of the Privacy Commissioner against Facebook based on 22 breaches of the Canadian Personal Information Protection and Electronic Documents Act (PIPEDA). University of Ottawa law students Lisa Feinberg, Harley Finkelstein, and Jordan Eric Plener, initiated the "minefield of privacy invasion" suit. Facebook's Chris Kelly contradicted the claims, saying that: "We've reviewed the complaint and found it has serious factual errors—most notably its neglect of the fact that almost all Facebook data is willingly shared by users." Assistant Privacy Commissioner Elizabeth