In 2004, the Supremes concurred that far less intrusive means, such as filters, existed to help parents deal with online pornography:

Congress should stick to narrowly focused content regulation strategies that look for the least intrusive means for protecting rights holders.

Mr. Starr will have to prove that not only is the advisers' testimony necessary, but that he cannot obtain the information through other, less intrusive means.

Additionally, the court held, the government's "important" interest in bringing the defendant to trial must be unattainable by alternative, less intrusive means.

The appeal argued that the state was constitutionally obliged to rely on less intrusive means than civil liability to protect the welfare of children in Christian Science families.

Military officials say they regard the letters as one of the least intrusive means to gather evidence.

In addition, courts must first consider "alternative, less intrusive means" before resorting to the involuntary administration of psychotropic medication.

The purpose of the EO is to ensure that Federal regulations seek more affordable and less intrusive means to achieve policy goals.

It also said the governor had to prove that his action served "a compelling state interest" and accomplished its goal "through the use of the least intrusive means."

A key element or key word here is proportionality, because it must be demonstrated convincingly that the same end cannot be achieved with less intrusive means.