In The Fourth Amendment and the Global Internet, Orin Kerr highlights several important Fourth Amendment questions that few courts have addressed. But in “offer[ing] a general framework for applying the Fourth Amendment to a global computer network in a way that maintains the existing territorial conception of the Fourth Amendment,” Kerr’s article focuses too narrowly on the Internet, the Verdugo-Urquidez sufficient connection test, and the border search exception. Such issues must, as Kerr acknowledges, be considered in broader context. This Essay proposes that courts maintain flexibility to conceive of a Fourth Amendment that does not depend exclusively on territory to fulfill its twin aims of ordering government and enabling redress of liberty infringements. It also encourages federal and state courts and legislatures to regulate searches, seizures, and surveillance through simple rules that can easily adapt to the contours of a rapidly evolving cyber landscape and new government activity in cyberspace.