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An, the model used by one of the perpetrators of the The FBI–Apple encryption dispute concerns whether and to what extent courts in the can compel manufacturers to assist in unlocking whose are. There is much debate over public access to strong encryption. In 2015 and 2016, has received and objected to or challenged at least 11 orders issued by under the of 1789. Most of these seek to compel Apple 'to use its existing capabilities to extract data like contacts, photos and calls from locked running on operating systems and older' in order to assist in criminal investigations and prosecutions. A few requests, however, involve phones with more extensive security protections, which Apple has no current ability to break. These orders would compel Apple to write new software that would let the government bypass these devices' security and unlock the phones.

The most well-known instance of the latter category was a February 2016 court case in the. The (FBI) wanted Apple to create and new software that would enable the FBI to unlock a work-issued it recovered from one of the shooters who, in in, killed 14 people and injured 22. The two attackers later died in a shootout with police, having first destroyed their personal phones. The work phone was recovered intact but was locked with a four-digit password and was set to eliminate all its data after ten failed password attempts. Apple declined to create the software, and a hearing was scheduled for March 22.

However, a day before the hearing was supposed to happen, the government obtained a delay, saying they had found a third party able to assist in unlocking the iPhone and, on March 28, it announced that the FBI had unlocked the iPhone and withdrew its request. In March 2018, the later reported 'the FBI eventually found that Farook's phone had information only about work and revealed nothing about the plot.' In another case in Brooklyn, a magistrate judge ruled that the could not be used to compel Apple to unlock an iPhone. The government appealed the ruling, but then dropped the case on April 22 after it was given the correct passcode. Chief Executive Officer of Cook and former FBI Director Comey have both spoken publicly about the case. In 1993, the (NSA) introduced the, an encryption device with an acknowledged for government access, that NSA proposed be used for phone encryption.