Case 2:16-mj-01061-TJR Document 13 Filed 02/03/17 Page 6 of 29 The Court of Appeals in Microsoft succinctly described the SCA's disclosure structure as follows: Regarding governmental access in particular, § 2703 sets up a pyramidal structure governing conditions under which service providers must disclose stored communications to the government. Basic subscriber and transactional information can be obtained simply with an administrative subpoena. 18 U.S.C. § 2703(c)(2). Other non-content records can be obtained by a court order (a"§ 2703(d) order"), which may be issued only upon a statement of "specific and articulable facts showing ... reasonable grounds to believe that the contents or records ... are relevant and material to an ongoing criminal investigation." § 2703(c)(2), (d). The government may also obtain some user content with an administrative subpoena or a§ 2703(d) order, but only if notice is provided to the service provider's subscriber or customer. § 2703(b)(l)(B). Microsoft, 829 F.3d at 207. The statutory provisions most relevant to the cases at bar pertain to the court's authority to issue a warrant requiring providers to disclose information and authorizing the Government to search the disclosed information. To obtain such user content, the Act generally requires the government to obtain a warrant that has been issued using the procedures set forth in Rule 41 of the Federal Rules of Criminal Procedure. See 18 U.S.C. § 2703(a)-(c). C. Federal Rule of Criminal Procedure 41 Rule 41 describes the procedures for the issuance of a search and seizure warrant. Of particular relevance here is Rule 41(b)(5) which provides the following: (5) a magistrate judge having authority in any district where activities related to the crime may have occurred, or in the District of Columbia, may issue a warrant for property that is located outside the jurisdiction of any state or district, but within the following: (A) a United States territory, possession, or commonwealth; (B) the premises - no matter who owns them - of a United States diplomatic or consular mission in a foreign state, including any 6