misapprehensions about fingerprint evidence that should call into question its value in individual cases and as a rationale for massive government surveillance operations like Operation Janus and Operation Second Look. The privacy concerns raised by systematic collection and digitization of biometric and other personal identifying information and the linking of government databases may be muted when such practices are directed toward non-citizens, or even naturalized citizens. But these developments are unfolding in a society currently engaged in debates about digital privacy, including revelations about government spying on U.S. citizens (born and naturalized) and non-citizens on a massive scale.444 Given this context, skepticism about the government’s approach should be seen as a responsible, even necessary endeavor, yet the reliability and materiality of fingerprint evidence for denaturalization cases has never been questioned. Database flaws. Today, fingerprint data submitted with naturalization applications is uploaded into two databases: DHS’s Automated Biometric Identification System (IDENT), established in 2007 and “built from a digital fingerprint repository originally deployed by INS in 1994,”445 and the FBI’s Next Generation Identification database (NGI), in use since 2014. From 1999 to 2014, the FBI used a database known as the Integrated Automated Fingerprint Identification System (IAFIS).446 IDENT houses data collected by Customs and Border Protection (CPB), ICE, USCIS, the Transportation Security Administration (TSA), and Department of State, among others. Before these systems were developed, earlier efforts to collect fingerprint information by U.S. agencies received extensive criticism, and the resulting data (card stock fingerprint files) is of questionable reliability. In 1994, an inspector general’s report as well as a DOJ study found that INS (a predecessor agency to DHS) could not verify that fingerprints on cards belonged to the applicants listed on the top portion of the card.447 These conditions prevailed when the cards now being digitized as part of Operation Janus and Operation Second Look were made. The OIG report notes several reasons why the information is of questionable reliability: Applicants for naturalization, permanent residency and other benefits completed fingerprint cards at local police departments, voluntary agencies (VOLAGs) or “other reputable organizations,” but the INS “ha[d] no effective controls” over other reputable organizations. INS had no way to ensure that such agencies verified the applicant’s identity. In most cases, [INS] would be unable to determine which organization was used because the card only contains the signature of the person taking the fingerprints and not the name of the fingerprint shop. In effect, a criminal alien, with his own ink pad, could take someone else’s prints and submit the card as his own to INS.448 II. Denaturalization: A Radical Measure in the Hands of Zealots 101