Signed by George W. Bush on October 26, 2001, forty-five days after the September 11 attacks, the USA PATRIOT Act (Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act) expanded FISA surveillance authorities, authorized roving wiretaps, broadened National Security Letter powers, and — in Section 215 — permitted the government to compel production of 'any tangible things' relevant to a foreign-intelligence investigation. Edward Snowden's 2013 disclosures revealed that the NSA had used Section 215 to collect Americans' phone metadata in bulk. In ACLU v. Clapper (2015) the Second Circuit held the program exceeded statutory authority; Congress reformed it in the USA FREEDOM Act (2015). The Section 215 authority itself lapsed in 2020.