subpoena, for extraterritoriality purposes, is on the place where the documents are stored, since in order to comply with a subpoena seeking documents stored abroad, corporate employees will have to be present in the foreign location where the documents exist to inspect and select the relevant documents, which will then have to be transported out of that location and into the United States. Electronic “documents,” however, are different. Their location on a computer server in a foreign country is, in important ways, merely virtual. See Orin S. Kerr, The Next Generation Communications Privacy Act, 162 U. Pa. L. Rev. 373, 408 (2014) (explaining that “the very idea of online data being located in a particular physical ‘place’ is becoming rapidly outdated,” because computer files can be fragmented and dispersed across many servers). Corporate employees in the United States can review those records, when responding to the “warrant” or subpoena or court order just as they can do in the ordinary course of business, and provide the relevant materials to the demanding government agency, without ever leaving their desks in the United States. The entire process of compliance takes place domestically. The government’s characterization of the warrant at issue as domestic, rather than extraterritorial, is thus far from frivolous, and renders this, for me, a very close case to the extent that the presumption against extraterritoriality shapes our interpretation of the statute. One additional potential fact heightens the complexity. We do not know, on this record, whether the customer whose emails were sought by the government is or is not a United States citizen or resident. It is not clear that whether the customer is a United States person or not matters to the rather simplistic “focus” test adopted by the Supreme Court in Morrison, although it would have mattered to the more flexible test utilized by the Second Circuit in that case. See Morrison v. 13