the subject of a written request or directive, or a series of written requests or directives, from the Attorney General or the head of an element of the intelligence community (or the deputy of such person) to the electronic communication service provider indicating that the activity was — (i) authorized by the President; and (ii) determined to be lawful;Judicial review is limited to a secret review that the request was made.
So that's that. Not even a fig leaf. If the president requested it and the AG certified it was legal, then telecom immunity is absolute. Some compromise. Neville Chamberlain would be proud.