Case 2:16-mj-01061-TJR Document 13 Filed 02/03/17 Page 24 of 29 Under the facts before this court, the conduct relevant to the SCA's focus will occur in the United States. That is, the invasions of privacy will occur in the United States; the searches of the electronic data disclosed by Google pursuant to the warrants will occur in the United States when the FBI reviews the copies of the requested data in Pennsylvania. These cases, therefore, involve a permissible domestic application of the SCA, even if other conduct (the electronic transfer of data) occurs abroad. See RJR Nabisco, 136 S. Ct. at 2101. 17 B. Other Considerations Having concluded that the record before the court does not present an extraterritorial application of the SCA, the court will address several other considerations raised by the parties, recognizing that such considerations are not determinative of the primary issue before the court. In this court's view, the analysis set forth above does not run afoul of principles of comity and also presents a commonsense interpretation of the SCA which will not lead to absurd results. 17 In contrast to the facts in Microsoft, there is no evidence in our record regarding the precise location of the servers which store the electronic data requested by the search warrants. Therefore, Google's case is easily distinguishable from the facts in Microsoft, wherein all the relevant user data of a presumably Irish citizen was located exclusively in one data center in Ireland and remained stable there for a significant period oftime. See Microsoft, 829 F.3d at 220 (finding "that the data is stored [exclusively] in Dublin, that Microsoft will necessarily interact with the Dublin data center in order to retrieve the information for the government's benefit, and that the data is within the jurisdiction of a foreign sovereign"). Indeed, a key assumption made by the majority in Microsoft was that "messages stored in the 'cloud' have a discernable physical location." Id. at 221 n.28. As explained supra, because of the changeable and divisible nature of Google's cloud technology, this critical assumption cannot be made in this case. See Jennifer Daskal, The Un-Territoriality of Data, 125 Yale L.J. 326, 379 (2015) ("The intermingling of data means that it is often difficult, if not impossible, to make the kind of finetuned identity- and location- based distinctions that Fourth Amendment ... law demands."). 24