Geofence warrant to Google was reasonable and sufficiently particular and nonintrusive. In re Search of Info. That Is Stored At Premises Controlled By Google, 2023 U.S. Dist. LEXIS 33651 (S.D. Tex. Feb. 14, 2023):
The application and resulting Step One warrant are also sufficiently specific as to what information is to be seized. The application seeks permission to seize as evidence only that information which falls into a specific category: Location History information stored on Google’s servers. That Location History information would be comprised of the Google-generated Reverse Location Obfuscation Identifier (RLOI), associated time stamp, margin for error, and data source from which the location was derived. The Location History information, further, relates to a specific, narrowly drawn location at specific, narrowly drawn periods of time. There is no discretion left to officers who will execute the warrant, because Google is being commanded to provide all of the specified Location History information relating to that specific geographic location and those specific dates and times, and nothing else.
The Court concludes that the requested warrant is sufficiently specific, and therefore satisfies the particularity requirement.