Daniel Solove’s work forms the basis of our recent analyses of big data privacy. It is impressive that he pulls together a comprehensive analysis of the implications of the passing of Justice Scalia for the third-party doctrine within a day. Justice Scalia’s opinion in Jones actually provides very little protection against government location tracking. Only the physical affixing of a GPS device to a car violates the 4th Amendment according to his view. But under the third party doctrine, the government can readily obtain GPS data from third parties that provide GPS services without a physical trespass to the car.