Most illuminating is how this documented chilling effect can be used,<p>&quot;Penney’s work may provide fodder for technology companies and others arguing for greater restraint and disclosure about intelligence-gathering. Chilling effects are notoriously difficult to document and so have limited impact on laws and court rulings.<p>More immediately, the research could aid a lawsuit filed by the American Civil Liberties Union on behalf of Wikipedia’s nonprofit parent organization and other groups against the NSA and the Justice Department.&quot;<p>A study over a long period of time on many articles helps avoid the noise of news.