persons who could approve the issuance of NSLs, from the FBI Director (or their designees) to include the FBI Special Agent in Charge of the 56 field offices. Contentious aspects Two contentious aspects of NSLs are the nondisclosure provision and judicial oversight when the FBI issues an NSL, both of which federal courts have held to be constitutional. When the Director of the FBI (or their designee) authorizes the inclusion of a nondisclosure provision in an NSL, the recipient may face criminal prosecution if it discloses the contents of the NSL or that it was received. The purpose of a nondisclosure provision is to prevent the recipient of an NSL from compromising the current FBI investigation involving for which the NSL was issued as well as future investigations (see 18 U.S.C. 2709), either of which would fetter the Government's efforts to address threats to national security. An NSL recipient (later revealed to be Nicholas Merrill) writing in The Washington Post said, [L]iving under the gag order has been stressful and surreal. Under the threat of criminal prosecution, I must hide all aspects of my involvement in the case ... from my colleagues, my family and my friends. When I meet with my attorneys I cannot tell my girlfriend where I am going or where I have been. Like other administrative subpoenas, NSLs do not require judicial approval. For NSLs, that is because the U.S. Supreme Court has held the type of information NSLs obtain do not have a constitutionally protected reasonable expectation of privacy. The person has already provided the information to a third party, e.g., their telephone company, so they no longer have a reasonable expectation of privacy to the information and, therefore, there is no Fourth Amendment requirement to obtain court approval to obtain the information. Nonetheless, an NSL recipient may still challenge the nondisclosure provision in federal court. A media report from 2007 stated a government audit found the FBI had violated the rules more than 1,000 times in an audit of 10% of its national investigations between 2002 and 2007. Twenty such incidents involved requests by agents for information not permitted under the law. A subsequent report in 2014 by the Justice Department Office of Inspector General concluded the FBI had corrected its practices and that NSLs now complied with federal law. According to 2,500 pages of documents the FBI provided to the Electronic Frontier Foundation