Courts have long acknowledged that searches of computers and other mediums storing electronic information (ESI) often involve a degree of intrusiveness much greater in quantity and in kind from searches of other containers. So one would have expected that given that the computer has been around for several decades including the use of the ubiquitous cell phone as one's "always at the ready" personal computer, the particularity rules for search warrants targeting ESI would be clearly defined. Sorry, kemo sabe, not today. Accordingly, this article will review some recent case law that spotlights this ever developing area of the law.