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In an essay for the Florida Law Review, Jon Penney, Danielle Keats Citron, and Alexis Shore Ingber explore the ways that the Dobbs decision spurred a level of "corporate surveillance of intimate life [that] chilled expressive activities," including users' use of search engines and period tracking apps, finding that (e.g.) the view counts for Wikipedia articles decreased following the Court's decision and ensuing conversations about data privacy.

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