IV. Who is covered

The Fourth Circuit reporter's privilege jurisprudence does not test the boundaries of whom the privilege protects. All of the case law has dealt with persons/entities and information fitting within traditional conceptions of "reporters" and "news." Thus, it is difficult to predict how the courts of the Circuit would classify nontraditional news gatherers, such as students or academic researchers, or nontraditional news outlets, such as newsletters, reports for investors or internet publications.