of particular targeted individuals, building a detailed understanding of the target’s patterns of behavior and social and professional contacts and activities. Network, application, and other technological developments are making that location information ever more detailed and precise. Considerable legal uncertainty surrounds the standards the government must satisfy to compel the production of location information, and achieving legal clarity is essential to protecting consumer privacy, defining the scope of legitimate law enforcement interests, and ensuring the efficient operation of companies operating in various sectors of the digital economy.

The case before the appeals court involves a Florida man, Quartavious Davis. He was sentenced to life for a string of robberies. His 2012 conviction rested largely on mobile phone records pegging his location near six of seven heists. The Atlanta-based appealsinstallation work under the contract
without incident. Sometime in early 2014, Lowe's decided to reduce the number of
flooring installers that serviced the 15 Lowe's stores located in central Ohio. Daniel S.
Vaughn, a Lowe's field services manager, told National that under this consolidation plan,
"National would be one of only two of the flooring installers working for Lowe's in the
area managed by Vaughn." (Hartman Aff. at 2.) Such a change would greatly increase the
revenues National received from installation jobs provided by Lowe's. However, Lowe's
No. 15AP-1010                                              