The Third Circuit in In re Application of U.S. for an Order Directing a Provider of Elec. Commc’n. Serv. to Disclose Records to Gov’t, 620 F.3d 304, 317–18 (3d Cir. 2010), heard the government’s appeal from an order of a magistrate judge declining to direct a service provider to furnish information by order under subsection (d) and requiring instead that the government pursue a warrant upon probable cause under subsection (c)(A). Briefly put, that circuit did vacate the magistrate judge’s denial, but opined that the magistrate judge in appropriate circumstances might “require a warrant showing probable cause . . . .” Id. at 319.