Use of civil investigative demands at the state and federal levels has increased dramatically in recent years. During this same time period, courts around the country have signaled their willingness to defer to investigative and law enforcement authorities’ judgment when it comes to the reasonableness of their demands. As a result, while it is theoretically possible to challenge a CID in court, providers and other companies will often find it more advantageous to attempt to work with the issuing authorities to limit their disclosure obligations.