Leavitt Communications, Inc., reports that "a recent survey of chief information officers and IT executives by market-research firm IDC rated security as their main cloud-computing concern. Almost 75% of respondents said they were worried about security" (Leavitt 2009, p 4). The US federal government would like to invest more heavily in cloud services, but the 2010 US federal budget cites security concerns: the federal community will need to actively put in place new security measures which will allow dynamic application use and information-sharing to be imple- mented in a secure fashion (United States Federal Budget 2010, p. 157)" (as cited in Paquette et al. 2010, p. 4). The White House's Consumer Data Privacy paper specifically notes that the USA is a world leader in the export of cloud computing and location-based services. but both national and international consumers must have faith in data privacy protection when using these services, or they will cease to use them (p. 6). In February 2012, both EU's Justice Commissioner Viviane Reding and the French data regulator CNIL announced that the proposed changes to the privacy policies of Google, one of the world's largest cloud operations, fa to meet the requirements of the European Data Protection Directive (95/46/CE). These recent disagreements underscore the immense legal complexity of transborder data movement facilitated by cloud computing (Pearson 2011).