requires the “warrant” not to authorize a search or seizure, but as the procedural mechanism to allow the government to “require a [service provider] to disclose the contents of [certain] electronic communication[s]” without notice to the subscriber or customer. 18 U.S.C. § 2703(b)(1)(A). Parallel provisions permit the government to require equivalent disclosure of the communications by the service provider by a simple administrative subpoena or by a court order, provided only that notice is provided to the subscriber. Id. § 2703(b)(1)(B).4 Indeed, the various methods of obtaining the communications, with or without notice, are not merely parallel – they all depend on the same verbal phrase. They are simply alternative means, applicable in different circumstances, to “require [the service provider] to disclose [the communications].” Id. § 2703(a), (b). argue that this sort of warrant is completely different from what its language tells us it is, and that the language is unimportant because the government simply used the same formal template it uses under other, more traditional circumstances involving physical searches. 4 One category of communications – those held “in electronic storage” by an electronic communication service for one hundred and eighty days or less – is reachable only by SCA warrant, with or without notice to the customer. 18 U.S.C. § 2703(a). But, although we ourselves have not addressed the issue, the majority view is that, once the user of an entirely web-based email service (such as Microsoft’s) opens an email he has received, that email is no longer “in electronic storage” on an electronic communication service. See Lazette v. Kulmatycki, 949 F. Supp. 2d 748, 758 (N.D. Ohio 2013); Crispin v. Christian Audigier, Inc., 717 F. Supp. 2d 965, 987 (C.D. Cal. 2010); United States v. Weaver, 636 F. Supp. 2d 769, 773 (C.D. Ill. 2009); Jennings v. Jennings, 736 S.E.2d 242, 245 (S.C. 2012); id. at 248 (Toal, C.J., concurring in the result); Kerr, A User’s Guide, supra, at 1216–18 & n.61; cf. Anzaldua v. Ne. Ambulance & Fire Prot. Dist., 793 F.3d 822, 840–42 (8th Cir. 2015) (message retained on Gmail server in “sent” folder was not in electronic storage). But see Cheng v. Romo, Civ. No. 1110007-DJC, 2013 WL 6814691, at *3–5 (D. Mass. Dec. 20, 2013); Pure Power Boot Camp v. Warrior Fitness Boot Camp, 587 F. Supp. 2d 548, 555 (S.D.N.Y. 2008); cf. Theofel v. FareyJones, 359 F.3d 1066, 1075–77 (9th Cir. 2003) (message is in electronic storage until it “has expired in the normal course”). Under that reading of the statute, only emails that have not yet been opened by the recipient fall into the category described above. 10