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That WaPo news has been debunked:

http://blog.erratasec.com/2013/07/no-nsa-cant-track-phones-e...

There is NSA method called 'implant', but it requires installation of software (possibly in the firmware). It's not so easy and it can't be used in large scale.

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Reading the blog post, it definitely does not 'debunk' the Washington Post report. All it does is take issue with Snowden's blanket claim that all mobiles are vulnerable (which is a good point and is one I'm inclined to agree with).

Let's not confuse mass surveillance and targeted surveillance of small number of people. They are two different things.

Snowden is right when he says that every phone is vulnerable for targeted surveillance. For people like him, every phone is dangerous even when they are closed.

Mass surveillance is different. NSA can't just pick random person and remotely track their phone when it's turned off.

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