While estimates vary, the number of globally Internet-connected devices now ranges anywhere from 20 to 30 billion—a staggering statistic that only becomes more staggering when considering the amount of data created by those devices. See Leading the IoT, Gartner, at 2; Gilad David Maayan, The IoT Rundown for 2020, Security Today (Jan. 13, 2020).

At a macro level, the "Internet of Things" or "IoT" describes "dedicated-function objects" connected to the Internet (e.g., refrigerators, vehicles, or washing machines). See Leading the IoT at 2. Traditionally, those devices performed singular functions without regard to any other devices or Internet data. But, as technology has infiltrated every aspect of our daily lives, consumers have grown accustomed to IoT devices—whether they know it or not. These IoT devices transmit data back and forth to centralized servers or data repositories, or they communicate with other devices in the home. For simplicity, we employ the term IoT devices to also include wearable devices, such as smart watches and sleep tracking devices.

IoT devices benefit from exponentially more data to make mundane tasks more efficient and customizable. For example, homeowners simply can open their doors to set off a chain reaction of smart devices connected to Wi-Fi, such as deactivating an alarm, changing the lighting and music, adjusting the thermostat, preheating the oven for dinner, and opening the blinds. Perhaps even more pertinent to litigation, health data and other personal information are routinely collected by many IoT devices. The latest Apple Watch Series 6 can now measure blood oxygen levels, take an ECG, and measure fitness and other health metrics. "Smart scales" can measure and transmit weight, BMI, heart rate, and body composition. And, of course, Alexa and Google Home are continuously "listening" to conversations throughout the home. See Grant Clauser, Amazon's Alexa Never Stops Listening to You. Should You Worry?, New York Times (Aug. 8, 2019).