Parallel construction also isn't out of the question for these VPN providers that have testified under oath. If I were the NSA I'd buy some "no logs" VPN providers that don't provide logs in court, but do have them to make catching criminals much easier.

It doesn't hurt that the "no logs under oath" assertion will no doubt engender trust with the very people you want to log.

> VPN providers that don't provide logs in court, but do have them

That doesn’t make sense. If the provider has the logs, they’ll be presented in court if the company is given a subpoena and the owners are American. No one is going to risk contempt and jail time for their customers.

The apperence of not having logs is useful for both the law enforcement and the VPN owner, so why whould they subpoena the logs? The VPN could leak some details to the law and in exchange the law mostly leaves them alone. And the law would get cases where they know that spending their time will pay of: Saying "yeah, the computer repair shop found CP on the guys computer", thinking "because we told them where to look".