Activists around the world have developed practices and are taking distinct measures to resist cyber-surveillance. These range from using code words and taking out mobile phone batteries during meetings to the use of privacy enhancing technologies. This article discusses such measures by providing interviews with activists from a variety of countries, as well as by analyzing documents from German law enforcement agencies in a recent case against activists. These documents reveal that the meta-data produced via mobile telephony is at least as important for law enforcement as the content of the calls. Furthermore, if there is not enough meta-data, law enforcement will produce it to get to know the whereabouts of activists. This article thus argues that a mutual relationship between resistance and surveillance unfolds as one side reacts to the practices of the other: as soon as activists advance in the protection of their contents of telecommunication, the surveilling parties concentrate on meta-data to explore the whereabouts of their targets. To counter this threat only the discontinuation of mobile phone use has been articulated.