At this moment in time, there is nothing certain with respect to the legal requirements for acquisition of cell site information by the government for the purpose of identifying the location of a cellular telephone and its user. However, it is likely there will be a future legislative solution in cell site tracking. Until then, it is suggested that law enforcement track judicial developments closely within their jurisdictions. Traditional law enforcement methods of tracking, such as a tracking device on a vehicle or placing a device inside a container fit within the analysis provided by the U.S. Supreme Court in United States versus Knotts and United States versus Karo. Traditional law does not provide law enforcement with clear-cut guidance in the area of cell phone technology and physical surveillance. Under the Communications Assistance for Law Enforcement Act (CALEA), access to information disclosing the physical location of the cell subscriber when sought through a pen register or trap and trace device was limited.