In 2018, an unnamed National Security Letter recipient petitioned the FBI to review three NSL nondisclosure orders it received in 2011. The U.S. District Court for the Southern District of California held that the indefinite gag orders did not violate the First Amendment and should stay in place "unless and until" the government determined otherwise. The recipient appealed to the Ninth Circuit in Case Number 18-56669. EFF and ACLU filed an amicus brief in support of the recipient.