In Sorrell v. IMS Health Inc., the U.S. Supreme Court held that Vermont's "Prescription Confidentiality Law" imposes content-based and speaker-based burdens on expression and, as such, is subject to heightened judicial scrutiny. Under this analysis, the Court struck down the law as unconstitutional, concluding that Vermont's justifications for the law did not outweigh the benefits of protecting the right of free speech, while also acknowledging that its ruling leaves unresolved the serious personal privacy issues stemming from computer-based data mining. In the wake of this decision, the Second Circuit has requested supplemental briefing on the implications of Sorrell for its pending case, United States v. Caronia, a criminal case in which a pharmaceutical sales representative was convicted of misbranding a drug by promoting it for several off-label uses.