A report issued by the office of Manhattan District Attorney Cyrus Vance Wednesday pushes for lawmakers to require Apple, Google, and other tech companies to allow a backdoor into smartphones that are encrypted.

NBC News reports that devices that operate on iOS and Android encrypt all content, by default. Without a pin or password, the information on the phone is inaccessible, even to law enforcement, courts, and the manufacturers.

According to Vance’s office, 111 criminal search warrants between September 2014 and October 2015 were unable to be conducted, due to encryption technology. The report says that the software has been a hindrance to investigations, as some evidence only exists on the smartphones.

Vance is one of a growing number of officials urging a way for law enforcement to be able to access encrypted data, following the Paris attacks. The report recommends that companies developing a smart phone operating system make sure information is available to those performing a warranted search. A federal statute is referenced, naming smartphones as “part of interstate and foreign commerce,” placing them under federal constitutional authority.

However, as acknowledged by Apple CEO Tim Cook, a “backdoor” may not even be realistically possible. “You can’t have a back door that’s just for the good guys,” Cook said, during an event last month. If a way around encrypted data was created, it could be used by anyone who found out about it. To advocates of security and privacy, this is too great of a risk.