Case 2:16-mj-01061-TJR Document 13 Filed 02/03/17 Page 9 of 29 Circuit's decision in Microsoft, Google routinely complied with federal courts' search warrants which commanded the production of user data stored on Google servers located outside the United States. (N.T. 1/12/17 at 8.) E. The Microsoft Decision The Microsoft decision was the result of an appeal from an order of the United States District Court for the Southern District of New York which denied Microsoft Corporation's motion to quash a search warrant. In that case, United States Magistrate Judge James C. Francis, IV, issued a search warrant pursuant to the SCA authorizing the search and seizure of information associated with a specific web-based email account maintained by Microsoft Corporation. Microsoft moved to quash the search warrant to the extent it required Microsoft to access user data stored and maintained on servers located in Ireland and import that data into the United States for delivery to federal authorities. In a comprehensive opinion, Judge Francis denied the motion to quash and held that the warrant did not violate the presumption against extraterritorial application of a law of the United States. In re Warrant to Search a Certain E-mail Account Controlled and Maintained by Microsoft Corp., 15 F.Supp. 3d 466 (S.D.N.Y. 2014). Judge Francis found that under section 2703 of the SCA, the term "a warrant issued using the procedures described in the Federal Rules of Criminal Procedure ... by a court of competent jurisdiction" is ambiguous regarding jurisdiction. Judge Francis explained as follows: This language is ambiguous in at least one critical respect. The words "using the procedures described in the Federal Rules of Criminal Procedure" could be construed to mean, as Microsoft argues, that all aspects of Rule 41 are incorporated by reference in Section 2703(a), including limitations on the territorial reach of a warrant issued under that rule. But, equally plausibly, the 9