This difference is significant if we are looking to determine the “focus” of the SCA for purposes of determining whether a particular application of the statute is or is not extraterritorial. See Morrison v. Nat’l Australia Bank Ltd., 561 U.S. 247, 266–69 (2010). A search warrant “particularly describing the place to be searched, and the persons or things to be seized,” U.S. Const. amend. IV, is naturally seen as focused on the place to be searched; as explained above, if the government argued that a statute authorized a search of a place outside the United States, that would clearly be an extraterritorial application of the statute. Here, however, the SCA warrant provision does not purport to authorize any such thing. Just like the parallel subpoena and court order provisions, it simply authorizes the government to require the service provider to disclose certain communications to which it has access.5 The government quite reasonably argues that 5 Although the Supreme Court has not addressed the question, there is considerable case law, including in this circuit, permitting the exercise of subpoena powers in precisely the situation in which the government demands records located abroad from an American company, or a foreign company doing business here. See, e.g., Linde v. Arab Bank, PLC, 706 F.3d 92 (2d Cir. 2013); United States v. Bank of Nova Scotia, 740 F.2d 817 (11th Cir. 1984); Marc Rich & Co., A.G. v. United States, 707 F.2d 663 (2d Cir. 1983); United States v. First Nat’l City Bank, 396 F.2d 897, 900–01 (2d Cir. 1968) (“It is no longer open to doubt that a federal court has the power to require the production of documents located in foreign countries if the court has in personam jurisdiction of the person in possession or control of the material.”). At least as far as American courts are concerned (some foreign governments may think otherwise), such demands for the production of records are not seen as categorically impermissible extraterritorial uses of American investigatory powers, in the way that search warrants for foreign locations certainly would be. Compare Restatement (Third) of Foreign Relations Law § 442(1)(a) (“A court or agency in the United States, when authorized by statute or rule of court, may order a person subject to its jurisdiction to produce documents, objects, or other information relevant to an action or investigation, even if the information or the person in possession of the information is outside the United States.”) with id. § 433(1) (“Law enforcement officers of the United States may exercise their functions in the territory of another state only (a) with the consent of the other state and if duly authorized by the United States; and (b) in compliance with the laws both of the United States and of the other state.”). Microsoft attempts to distinguish the cases cited above on the ground that the subpoenas in those cases required their recipients to disclose only the contents of their own business records, and not the records of a third party “held in trust” by the recipients. Appellant’s Br. 48. 11