UNITED STATES V. MOHAMUD 39 Zakharov, 468 F.3d 1171, 1179 (9th Cir. 2006) (citing United States v. Verdugo-Urquidez, 494 U.S. 259, 274–75 (1990)); see also Verdugo-Urquidez, 494 U.S. at 274–75 (“At the time of the search, [respondent] was a citizen and resident of Mexico with no voluntary attachment to the United States, and the place searched was located in Mexico. Under these circumstances, the Fourth Amendment has no application.”). Thus, the government’s monitoring of the overseas foreign national’s email fell outside the Fourth Amendment. Mohamud argues that under Verdugo-Urquidez, the location of the search matters, and that here, the searches took place in the United States.22 Indeed, the government acknowledges that “collection from service providers under Section 702 takes place within the United States.” Yet, as one court put it, “what matters here is the location of the target,” and not where the government literally obtained the electronic data. United States v. Hasbajrami, No. 11-CR623, 2016 WL 1029500, at *9 n.15 (E.D.N.Y. Mar. 8, 2016) (emphasis in original); see also Kris & Wilson, National Security Investigations & Prosecutions § 17:3 (2016) (“For non-U.S. person targets, there is no probable-cause requirement; the only thing that matters is [ ]the government’s reasonable belief about[ ] the target’s location.”). Consistent with Verdugo-Urquidez and our precedent, we hold that this particular type of non-upstream collection— 22 Mohamud also argues that the targeted foreign national may have had sufficient “voluntary connection[s]” to the United States for the Fourth Amendment to apply. See Verdugo-Urquidez, 494 U.S. at 271, 273. We have reviewed the classified record, and are satisfied that is not the case here.