Thousands of hours must be spent reviewing and producing documents (trolls have no documents to produce).

FORBES: Turn The Tables On Patent Trolls

Judge Walton wrote in his opinion, the First Amendment does not protect news reporters or news organizations from producing documents when the news reporters are, themselves, critical to both the indictment and prosecution of criminal activity.

NPR: Journalists' Documents Sought in CIA Leak Case

Of course, many recipients of these subpoenas face the very quandary the Fifth Amendment was designed to protect against: producing documents in response to the subpoena would concede that they violated the reporting requirements applicable to offshore accounts.

FORBES: Required Records, The Act Of Production And Secret Offshore Accounts