Circuit ruled that nondisclosure provisions were permissible only when the FBI certified that disclosure may result in certain statutorily enumerated harms (see, e.g., 18 U.S.C. 2709), and held the nondisclosure provision to a strict scrutiny standard. The Second Circuit then returned the case to the district court based on amendments to the USA PATRIOT Act that Congress had enacted while the case had been on appeal. Another effect of Doe v. Ashcroft was increased congressional oversight. The amendments to the USA PATRIOT Act mentioned above included requirements for semiannual reporting to Congress. Although the reports are classified, a nonclassified accounting of how many NSLs are issued is also required. On April 28, 2006, the Department of Justice reported to the House and Senate that in calendar year 2005, "The Government made requests for certain information concerning 3,501 United States persons pursuant to NSLs. During this period, the total number of NSL requests ... for information concerning U.S. persons totaled 9,254." In 2010, the FBI agreed to lift partially the nondisclosure provision to allow Merrill to reveal his identity. On August 28, 2015, Judge Marrero rescinded the nondisclosure provision associated with the NSL Merrill had received, thereby allowing him to speak about the contents of the NSL. On November 30, 2015, the unredacted court ruling was published in full. See also Lettre de cachet Non-disclosure agreement Warrant canary Transparency Report DSMA-notice References External links National Security Letters in Foreign Intelligence Investigations: A Glimpse of the Legal Background and Recent Amendments (PDF) Doe v. Ashcroft decision (PDF) Decision of the United States Court of Appeals for the Second Circuit in re: John Doe I et al. v. Alberto Gonzales et al. (PDF) Documentary film : FBI Unbound: How National Security Letters Violate Our Privacy Thousands of Declassified National Security Letters from various government agencies Censorship in the United States Federal Bureau of Investigation Legal documents Mass intelligence-gathering systems Surveillance scandals Patriot Act