Case 2:16-mj-01061-TJR Document 13 Filed 02/03/17 Page 8 of 29 At oral argument, counsel for Google explained that each year Google receives over 25,000 pieces oflegal process from federal, state, and local governmental entities seeking the disclosure of user data in criminal matters. (N.T. 1112117 at 7.) Only Google personnel in Google's Legal Investigations Support team are authorized to access the content of communications in order to produce it in response to legal process. (Stip. ~ 5.) All such Google personnel are located in the United States. Id. Thus, Google discloses data to the Government by having one of its authorized employees in the United States access the data through its computers located in the United States. Indeed, Google admits that this is the only way data can be accessed in response to legal process and the Government has no other available process to obtain the data. 6 (Stip. ~ 5; N.T. 1/12/17 at 17.) Google avers that it has fully complied with the warrants at issue in that it has "produced all records identified with sufficient particularity that are responsive to the warrant(s)." (Google Resp. at 4.) Relying on Microsoft, Google posits that a warrant issued under the SCA "lawfully reaches only data stored within the United States." Id. (citing Microsoft, 829 F.3d at 222). According to Google, it has "already produced all records that it can ascertain are stored within the United States." Id. It further contends that the warrants at issue here cannot compel Google to produce records that are or may be stored outside the United States. Id. To date, therefore, Google has produced only responsive data which it has confirmed to be stored in the United States. See Deel. of John R. Tyler at~~ 1-4. Prior to the Second 6 At oral argument, when asked how the Government could obtain the sought-after data absent Google's production of the data in accordance with the Government's SCA warrant, Google's counsel indicated that the Government could work to reform the SCA. (N.T. 1/12/17 at 17.) 8