While the FBI’s recent order for Apple to unlock iPhones for the purpose of Federal investigations [into the San Bernadino shootings (among, perhaps, other incidents)] might have taken center stage recently it seems the government agency has also pursued similar orders for Android phones. A recent study claims that the Feds have ordered Google to unlock at least nine Android phones since 2012.

As a matter of fact, new data from the American Civil Liberties Union indicates at least 63 cases in which the US government has been compelled to order Apple or Google to unlock a mobile handset. While it remains clear how many of these orders have actually been issued—or filled—it is also uncertain how many of these cases might have been issued and/or resolved before this most recent incident.

Android Device Master UnlocksAccording to a Google spokesperson, “We carefully scrutinize subpoenas and court orders to make sure they meet both the letter and spirit of the law. However, we’ve never received an All Writs Act order like the one Apple recently fought that demands we build new tools that actively compromise our products’ security. As our amicus shows, we would strongly object to such an order.”

Google, of course, claims they do not have direct access to the software that runs Android phones, in a defense very similar to Apple’s in the recent security case. At the same time, Google does manage many of the lockscreen protection programs through the Android Device Manager, which is particularly interesting in a case like this since iPhones are only of a particular make but Android devices can be manufactured by Samsung, Alcatel, Nokia, Kyocera, Motorola, and more. Many of these brands, in fact, ship without default device encryption that can block the use of traditional forensic extraction tools (as used in the San Bernadino case), but all iPhones come with the default encryption pre-installed.

The purpose for Google to remain uninvolved with the software running on Android phones is, of course, to increase usability features on phones. These features allow Android users to reset their lockscreen passcode if they get locked out (after too many failed attempts, for example). The feature only works on phones that have an unlock pattern—and do not, say, use fingerprint, password, or PIN verification—but has been discontinued since Android Lollipop.

According to the ACLU, though, the same type of password reset should be available to law enforcement, allowing officials to access an otherwise secure device by resetting the passcode.

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