Yochai Benkler , author of the 2006 book The Wealth of Networks , described the "Networked Fourth Estate" in a May 2011 paper published in the Harvard Civil Liberties Review .  He explains the growth of non-traditional journalistic media on the Internet and how it affects the traditional press using Wikileaks as an example. When Benkler was asked to testify in the United States vs. PFC Bradley E. Manning trial, in his statement to the morning 10 July 2013 session of the trial he described the Networked Fourth Estate as the set of practices, organizing models, and technologies that are associated with the free press and provide a public check on the branches of government.    :28–29 It differs from the traditional press and the traditional fourth estate in that it has a diverse set of actors instead of a small number of major presses. These actors include small for-profit media organizations, non-profit media organizations, academic centers, and distributed networks of individuals participating in the media process with the larger traditional organizations.  :99–100
In my view, courts should try to answer these questions by translating the traditional protections of the Fourth Amendment from the physical world to the networked world. In the physical world, the Fourth Amendment strikes a balance. The government is free to do many things without constitutional oversight. The police can watch people in the public street or watch a suspect in a public place. They can follow a car as it drives down the street. On the other hand, the police need cause to stop people, and they need a warrant to enter private places like private homes.