At the daily briefing on Thursday, Carney again refused to answer repeated questions about whether the US had spied on Merkel's calls in the past.
The NSA memo seen by the Guardian was written halfway through George W Bush's second term, when Condoleezza Rice was secretary of state and Donald Rumsfeld was in his final months as defence secretary.
Merkel, who, according to Reuters, suspected the surveillance after finding her mobile phone number written on a US document, is said to have called for US surveillance to be placed on a new legal footing during a phone call to President Obama.
"The [German] federal government, as a close ally and partner of the US, expects in the future a clear contractual basis for the activity of the services and their co-operation," she told the president.
The leader of Germany's Green party, Katrin Goring-Eckhart, called the alleged spying an "unprecedented breach of trust" between the two countries.
Earlier in the week, Obama called the French president François Hollande in response to reports in Le Monde that the NSA accessed more than 70m phone records of French citizens in a single 30-day period, while earlier reports in Der Spiegel uncovered NSA activity against the offices and communications of senior officials of the European Union.
The European Commission, the executive body of the EU, this week backed proposals that could require US tech companies to seek permission before handing over EU citizens' data to US intelligence agencies, while the European parliament voted in favour of suspending a transatlantic bank data sharing agreement after Der Spiegel revealed the agency was monitoring the international bank transfer system Swift.
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