Case 2:16-mj-01061-TJR Document 13 Filed 02/03/17 Page 11 of 29 Microsoft to withhold the data stored in Ireland would force the Government to rely solely on Mutual Legal Assistance Treaties ("MLAT"s) to obtain information stored abroad. Judge Francis found that this could not have been Congress' intent as the process under a MLAT is "slow and laborious" and many countries have no MLAT with the United States. Id. at 474-75. Finally, Judge Francis noted that "the concerns that animate the presumption against extra territoriality are simply not present here." "[A]n SCA Warrant does not criminalize conduct taking place in a foreign country; it does not involve the deployment of American law enforcement personnel abroad; it does not require even the physical presence of service provider employees at the location where data are stored. At least in this instance, it places obligations only on the service provider to act within the United States." Id. at 475. On July 31, 2014, Chief Judge Loretta A. Preska of the United States District Court for the Southern District of New York affirmed Magistrate Judge Francis' denial of the motion to quash. See In re Warrant to Search a Certain E-Mail Account Controlled and Maintained by Microsoft Corp., 2014 WL 4629624 (S.D.N.Y. Aug. 29, 2014). On appeal, the Second Circuit reversed. Microsoft, 829 F.3d 194 (2d Cir. 2016). The majority opinion was authored by the Honorable Susan L. Carney and joined by District Judge Victor A. Bolden. Circuit Judge Gerard E. Lynch filed a concurring opinion. Significant to the Second Circuit's analytic framework in Microsoft is the principle of construction utilized by the United States Supreme Court in Morrison v. Nat'l Australia Bank Ltd., 561 U.S. 247 (2010). The Second Circuit noted the presumption against extraterritorial application of United States statutes analyzed in Morrison to be "strong and binding." Microsoft, 829 F.3d at 209. The court stated: 11