The key word in that sentence being "targeting". A lot of the discussion is on what happens when the NSA targets a non-American overseas and that person calls

The key word in that sentence being "targeting". A lot of the discussion is on what happens when the NSA targets a non-American overseas and that person calls or communicates with someone in the US. If you can listen to a large amount of an overseas target's communications, it's inevitable that some of what you pick up will be communications with Americans. The questions, and confusion, is what happens and what should happen when that occurs. The problem is that so much of the reporting around this gets things confused that it is hard to understand what everyone is talking about, and a lot of people are walking away with the assumption that analysts in the NSA are regularly listening to US-to-US phone calls or emails for shits and giggles.