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by rule_follower 2860 days ago
Those are actions with judicial oversight. I believe OP was referring to NSLs and other IC actions.
1 comments

NSLs are counted here, and ones without non-disclosure obligations have the actual letter published.

https://transparencyreport.google.com/user-data/us-national-...

Should have specified NSLs that cannot be disclosed but the IC activity is far more significant.
It appears even NSLs that cannot be disclosed are still counted in the published numbers. IC is Intelligence Community? I would assume google would warn users of phishing attacks by the NSA just as they would warn users of phishing attacks by Iran.