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 type of information to convey far more than previously possible.” Id. at 394. Just by looking at one category of information—for example, “a thousand photographs labeled with dates, locations, and descriptions” or “a record of all [a defendant’s] communications … as would routinely be kept on a phone”—“the sum of an individual’s private life can be reconstructed.” Id. at 394–95. In short, Riley rejected the premise that permitting a search of all content on a cellphone is “materially indistinguishable” from other types of searches. Id. at 393. Absent unusual circumstances, probable cause is required to search each category of content. Id. at 395 (stating that “certain types of data” on cellphones are “qualitatively different” from other types); id. at 400 (analyzing data from a phone’s call log feature separately); see also Carpenter v. United States, 138 S. Ct. 2206, 2217 (2018) (analyzing data from a phone’s cell tower location signals separately).

This distinction dovetails with the Fourth Amendment’s imperative that the “place to be searched” be “particularly describ[ed].” amend. IV.; cf., e.g., United States v. Beaumont, 972 F.2d 553, 560 (5th Cir. 1992) (“General warrants [which lack particularity] have long been abhorred in the jurisprudence of both England and the United States.”). Probable cause and particularity are concomitant because “—at least under some circumstances—the lack of a more specific description will make it apparent that there has not been a sufficient showing to the magistrate that the