protect all communications and consumer records, mainly because the law is so outdated and out of touch with how people currently share, store, and use information. Under ECPA, it is relatively easy for a government agency to demand service providers hand over personal consumer data stored on the service provider's servers. Email that is stored on a third party's server for more than 180 days is considered by the law to be abandoned. All that is required to obtain the content of the emails by a law enforcement agency is a written statement certifying that the information is relevant to an investigation, without judicial review. When the law was initially passed, emails were stored on a third party's server for only a short period of time, just long enough to facilitate transfer of email to the consumer's email client, which was generally located on their personal or work computer. Now, with online email services prevalent such as Gmail and Hotmail, users are more likely to store emails online indefinitely, rather than to only keep them for less than 180 days. If the same emails were stored on the user's personal computer, it would require the police to obtain a warrant first for seizure of their contents, regardless of their age. When they are stored on an internet server however, no warrant is needed, starting 180 days after receipt of the message, under the law. In 2013, members of the U.S. Congress proposed to reform this procedure. ECPA also increased the list of crimes that can justify the use of surveillance, as well as the number of judicial members who can authorize such surveillance. Data can be obtained on traffic and calling patterns of an individual or a group without a warrant, allowing an agency to gain valuable intelligence and possibly invade privacy without any scrutiny, because the actual content of the communication is left untouched. While workplace communications are, in theory, protected, all that is needed to gain access to communiqué is for an employer to simply give notice or a supervisor to report that the employee's actions are not in the company's interest. This means that, with minimal assumptions, an employer can monitor communications within the company. The ongoing debate is, where to limit the government's power to see into civilian lives, while balancing the need to curb national threats. In 2011, The New York Times published "1986 Privacy