stored electronic communications, i.e., the Stored Communications Act ( et seq.), and added so-called pen/trap provisions that permit the tracing of telephone communications ( et seq.). provides for gag orders which direct the recipient of a pen register or trap and trace device order not to disclose the existence of the pen/trap or the investigation. Employee privacy The ECPA extended privacy protections provided by the Omnibus Crime Control and Safe Streets Act of 1968 (of employers monitoring of employees phone calls) to include also electronic and cell phone communications. See also Employee monitoring and Workplace privacy. Case law Several court cases have raised the question of whether e-mail messages are protected under the stricter provisions of Title I while they were in transient storage en route to their final destination. In United States v. Councilman, a U.S. district court and a three-judge appeals panel ruled they were not, but in 2005, the full United States Court of Appeals for the First Circuit reversed this opinion. Privacy advocates were relieved; they had argued in amicus curiae briefs that if the ECPA did not protect e-mail in temporary storage, its added protections were meaningless as virtually all electronic mail is stored temporarily in transit at least once and that Congress would have known this in 1986 when the law was passed. (see, e.g., RFC 822). The case was eventually dismissed on grounds unrelated to ECPA issues. The seizure of a computer, used to operate an electronic bulletin board system, and containing private electronic mail which had been sent to (stored on) the bulletin board, but not read (retrieved) by the intended recipients, does not constitute an unlawful intercept under the Federal Wiretap Act, 18 U.S.C. s 2510, et seq., as amended by Title I of ECPA. Governments can actually track cell phones in real time without a search warrant under ECPA by analyzing information as to antennae being contacted by cell phones, as long as the cell phone is used in public where visual surveillance is available. In Robbins v. Lower Merion School District (2010), also known as "WebcamGate", the plaintiffs charged that two suburban Philadelphia high schools violated ECPA by remotely activating the webcams embedded in school-issued laptops and monitoring the students at home. The schools admitted to secretly snapping over 66,000 webshots and screenshots, including webcam shots of students in their bedrooms. Criticism ECPA has been criticized for failing to