Case 2:16-mj-01061-TJR Document 13 Filed 02/03/17 Page 27 of 29 In Microsoft, the Government alleged that preventing SCA warrants from reaching data stored abroad would place a substantial burden on the Government; the Government further argued that the current process for obtaining foreign-stored data is cumbersome. Microsoft, 829 F.3d at 221. That process is governed by a series of MLATs between the United States and other countries, pursuant to which signatory states may request one another's assistance with ongoing criminal investigations, including the power to summon witnesses, to compel the production of documents and other real evidence, to issue search warrants, and to serve process. See U.S. Dep't of State, 7 Foreign Affairs Manual (FAM)§ 962.1 (2013), https://fam.state.gov/FAM/07FAM/07FAM0960.html. But as the district court in Microsoft found, the process under an MLAT is "slow and laborious" and many countries have no MLAT with the United States. Microsoft, 15 F.Supp. 3d at 474-75. This concern was echoed by Judge Cabranes in his opinion dissenting from the denial of en bane review of the Microsoft decision. Judge Cabranes stated: The United States has entered into MLATs with several countries, allowing parties to the treaty to request assistance with ongoing criminal investigations, including issuance and execution of search warrants. However, many countries do not have MLATs with the United States, ~' Indonesia and Pakistan, and law enforcement cooperation with those countries is limited. 2017 WL 362765, at *8 n.11. In addition, the Government argues that Google's architecture creates an insurmountable obstacle for the Government to overcome in the MLAT process. The location of the electronic data depends "upon the working of an automatic computer algorithm aimed at creating network efficiency." See Gov't Reply at 20. The Government seeks to draw a distinction between Microsoft and the present case. In Microsoft, the ISP could inform the 27