In United States v. Carey, 172 F.3d 1268 [10th Cir. 1999] a detective, after having obtained a warrant to search a computer for evidence of drug dealing, viewed the directories of the computer's hard drive. The detective noticed that there were numerous files with sexually suggestive titles which were labeled "JPG," indicating that they contained images. After downloading the contents of the hard drives onto floppy discs, the detective performed a "key word" search of text-based files, attempting to locate files containing terms which might be used by a drug dealer, but was not successful. The detective then opened one of the JPG files and discovered that it contained child pornography. Rather than seeking a new warrant authorizing a search for files containing child pornography, the detective proceeded to open numerous other image files containing pornographic matter. In opposing defendant's motion to suppress, the prosecutor argued that the image files were lawfully observed "in plain view" during the course of the search pursuant to the warrant. The prosecutor offered the analogy that officers searching a file cabinet pursuant to a warrant may seize any incriminating documents in plain view which they may find in the file cabinet regardless of whether they are covered by the warrant. Nonetheless, the court ruled that once the first file containing child pornography was opened, subsequent files containing pornography were not "inadvertently discovered" and had to be suppressed. (Id. at 1273.) While granting the defendant's suppression motion, the court suggested that the result might have been different if the computer files had been "ambiguously labeled." (Id. at 1275.)