In the face of increasing security measures on consumer devices, the US Department of Justice appears to be returning to old school tactics to get at data in devices. A judge in New York ordered an unnamed smartphone manufacturer to provide technical assistance in unlocking a device, something prosecutors argued under the All Writs Act of 1789. While the All Writs Act has been used in the past in technological situations, it could be the de facto means of law enforcement data requests in the future.