With technology changing and improving as quickly as ever, it stands to reason that the law is often behind the times, and regularly needs to catch up. This is precisely where the law currently stands regarding cell phones. It seems as though cell phone technology improves on a regular basis. These changes result in laws that are outdated and a need for increased scrutiny by the courts. Estimates suggest that in 2013, there were approximately 335.65 million wireless subscriber connections. Additionally, there were nearly 304,360 cell towers in the United States. In 2012, Verizon Wireless received an estimated 270,000 law enforcement requests for information about customers’ cell phone usage. Similarly, AT&T received 301,816 federal, state, and local criminal and civil investigation demands for cell phone information.