1984 is back. George Orwell’s nightmare vision of governmental surveillance, secrecy, and deception clearly resonates with the revelations first leaked to the Guardian by former National Security Agency (NSA) contractor Edward Snowden. Indeed, it is practically impossible to find an account of the Snowden affair without at least one ‘Orwellian’ adjective dropped into the mix. Sometimes it comes qualified: Justice Richard J. Leon, District Court Judge for the District of Columbia ruling in December 2013 that the bulk collection of US mobile phone records was probably unconstitutional, called the NSA program ‘almost Orwellian’. This decision is currently under appeal.