Case 2:16-mj-01061-TJR Document 13 Filed 02/03/17 Page 15 of 29 civil RICO plaintiff to allege and prove a domestic injury to business or property and does not allow recovery for foreign injuries. Id. at 2111. 9 II. DISCUSSION Much like the issues presented in Microsoft, the present dispute centers on the nature and reach of the warrants issued pursuant to the SCA. The court must determine whether the Government may compel Google to produce electronic records relating to user accounts pursuant to search warrants issued under section 2703 of the SCA, or in the alternative, whether Google has provided all records in its possession that the Government may lawfully compel Google to produce in accordance with the Second Circuit's ruling in Microsoft. The Government urges this court to depart from the Second Circuit's reasoning in Microsoft and compel disclosure by Google of the relevant electronic data. See Gov't Reply at 3-25. The Government argues that the Microsoft decision is incorrect, inconsistent with the weight of authority, not binding on this court, and should not be followed. For the reasons that follow, this court concludes that compelling Google to disclose to the Government the data that is the subject of the warrants does not constitute an unlawful extraterritorial application of the Act. 9 Since the RJR Nabisco case was decided, other courts have applied the RJR Nabisco interpretation of the Morrison second step. See, e.g., Adhikari v. Kellogg Brown & Root, Inc., 845 F.3d 184, 194-96 (5th Cir. 2017) (following guidance ofRJR Nabisco and analyzing whether there was any domestic conduct relevant to the plaintiffs' claims under the Alien Tort Statute); see also Tatung Co., Ltd. v. Shu Tze Hsu, 2016 WL 6683201, at *8 (C.D. Cal. Nov. 14, 2016) (analyzing whether the plaintiff suffered a domestic injury to business or property for the purposes of civil RICO's private right of action); Bascufian v. Daniel Yarur ELS Amended ComplaintA, 2016 WL 5475998, at *6 (S.D.N.Y. Sept. 28, 2016) (to determine whether a plaintiff may maintain a private cause of action under § 1964(c), the court must consider where the alleged injury was suffered). 15