Kevin was involved in a series of robberies of computer stores in the tri-state area. The FBI subpoenaed stored phone records for a period of four months. This enabled them to match Kevin's cell phone site locations with those where the robberies took place. It turned out that Kevin's cell phone signaled to towers in the vicinity of each of the robberies at the time the crimes took place. Kevin's attorney seeks to quash the subpoena.

Will he be successful?

a Yes, because of the overbreadth doctrine

b No, because phone records are non-content information

c No, because of the third party doctrine

d Yes, because this kind of continuous monitoring implicates Fourth Amendment privacy interests which require that a warrant be issued