Frank Sensenbrenner actually said...

We are not going to take that kind of 'no' for an answer.

How can Section 215 be utilized to scoop up the phone records of American citizens who are not in communication with a foreigner?

I had a hand in drafting, requires that the business records FISA warrants, or orders, be directed solely at foreigners.

There are no due process protections in place because the recipient of the FISA warrant can't tell what records he's turned over.