See Joe Sharkey, At U.S. Borders, Laptops Have No Privacy, N.Y. Times, October 24, 2006, at C 8. Both the Fourth and Ninth Circuit Courts of Appeal have held that Customs officers may conduct routine searches of laptops without a warrant, without probable cause, and without a reasonable suspicion of illegal conduct. See United States v. Romm, 455 F.3d 990, 996-97 (9th Cir. 2006); United States v. Ickes, 393 F.3d 501, 503-07 (4th Cir. 2005). Although a trial court in the Ninth Circuit recently ruled that Customs officers may not search a laptop or other electronic files without at least a reasonable suspicion of wrongdoing, United States v. Arnold, 2006 WL 2861592 (C.D. Cal. October 2, 2006), appeal docketed, No. 06-50581 (9th Cir.October 23, 2006), it is unclear whether that decision will survive on appeal.