A federal magistrate judge from the U.S. District Court for the Southern District of New York ruled, inIn Re Order Requiring [XXX], Inc. to Assist in the Execution of a Search Warrant Issued by this Court by Unlocking a Cellphone, that the government can compel a cell-phone manufacturer to help unlock a password-protected device in order to enable police to execute a search warrant.  Magistrate Judge Gabriel Gorenstein approved the order with the caveat that the manufacturer must have an opportunity to dispute it if compliance would be unreasonably burdensome.  According to the decision, most court orders seeking technical assistance are often deemed not to be burdensome.  However, as manufacturers such as Apple and Google implement their recently announced plans to install default encryption on their devices that they themselves are unable to bypass or unlock, orders like the one in this case may be rendered a nullity.