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itself in public view. When it comes to privacy, however, precedent suggests that the whole may be more revealing than the parts. Applying that precedent to the circumstances of this case, we hold the information the police discovered using the GPS device was not constructively exposed. (i). Precedent The Supreme Court addressed the distinction between a whole and the sum of its parts in United States Department of Justice v. National Reporters Committee, 489 U.S. 749 (1989), which arose not under the Fourth Amendment but under the Freedom of Information Act, 5 U.S.C. $ 552. There the respondents had requested, pursuant to the FOIA, that the FBI disclose rap sheets compiling the criminal records of certain named persons. Although the "individual events in those summaries [were] matters of public record, the Court upheld the FBI's invocation of the privacy exception to the FOIA, holding the subjects had a privacy interest in the aggregated "whole" distinct from their interest in the "bits of information' of which it was composed. Id. at 764.FN* Most relevant to the Fourth Amendment, the Court said disclosure of a person's rap sheet "could reasonably be expected to constitute an unwarranted invasion of personal privacy." Id. FN* The colloquialism that "the whole is greater than the sum of its parts' is not quite correct. "It is more correct to say that the whole is something different than the sum of its parts." Kurt Koffka, Principles of Gestalt Psychology 176 (1935). That is what the Court was saying in Reporters Committee and what we mean to convey throughout this opinion The Court implicitly recognized the distinction between the whole and the sum of the parts in the Fourth Amendment case of Smith v. Maryland, 442 U.S. 735 (1979). There. in holding the use of a pen register to record all the numbers dialed from a person's phone was not a search, the Court considered not just whether a reasonable person expects any given number he dials to be exposed to the phone company but also whether he expects all the numbers he dials to be compiled in a list. Id. at 742-43 ("subscribers realize... the phone company has facilities for making permanent records of the numbers they dial, for they see a list of their long-distance (toll) calls on their monthly bills'; they "typically know that ... the phone company has facilities for recording' the numbers they dial). The Court explained that Smith could not reasonably expect privacy in the list of numbers because that list was composed of information that he had "voluntarily conveyed to [the company]' and that "it had facilities for recording and .. was free to record." Id. at 745. *13 If, for the purposes of the Fourth Amendment, the privacy interest in a whole could be no greater (or no different) than the privacy interest in its constituent parts, then the Supreme Court would have had no reason to consider at length whether Smith could have a reasonable expectation of privacy in the list of numbers he had called. Indeed, Justice Stewart dissented specifically because he thought the difference was significant on the facts of that case. See id, at 747 ("such a list [of all the telephone numbers one called] easily could reveal ... the most intimate details of a person's life') 16 007097 TTU^OTD