Kate Martin, for example, says that "even a general examination of telecommunications history … reveals that the scenario they posit is not accurate. While satellites were increasingly used in the 1970s … American telephone companies were continuing to rely on trans-oceanic cables for international calls, with newer transatlantic cables sunk even the year after FISA passed." In fact, Martin asserts, some technological developments, including cordless phones and cell phones, have increased the use of radio waves since FISA became law.