It's a strained legal analogy to the pre-digital world. A hundred years ago, cops were able to seize a key to a keylocked vault as seizing property, but they couldn't force you to tell them the combination to a combolocked vault as that would violate fifth amedment right from self-incrimination. I agree in the modern digital era that doesn't make any sense, but originally that's how the distinction was made.
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