To put HSI’s estimate into perspective, a previous WIRED analysis found that in the more than six and a half years from the start of 2016 to mid-August 2022, ICE agents only sent out around 170,000 of a type of administrative subpoena called a 1509 customs summons. The number of administrative subpoenas was revealed as part of a Freedom of Information Act lawsuit against the Department of Homeland Security filed by the Electronic Frontier Foundation.