The federal Stored Communications Act (SCA), 18 U.S.C. §§ 2701-2712, restricts the ability of network service providers to voluntarily disclose information about their customers. The SCA, however, provides a “complete defense” to parties that produce documents in “good faith reliance on … a grand jury subpoena.” In Sams v. Yahoo! Inc., 713 F.3d 1175 (9th Cir. 2013) (No. 11-16930), Yahoo! received a faxed grand jury subpoena from a Georgia District Attorney’s office, requesting information regarding the identity of a user, who was later determined to be the plaintiff. Yahoo! complied with the subpoena and timely produced the requested information. Plaintiff sued Yahoo, claiming that the subpoena was invalid under Georgia law and, therefore, Yahoo! violated the SCA when it voluntarily disclosed plaintiff’s subscriber information to the government. The district court dismissed the case, holding that Yahoo! fell within the SCA’s good-faith defense. In affirming, the Ninth Circuit held, as a matter of first impression in that circuit, that the SCA’s good-faith defense is met when the defendant complies with a subpoena (even an invalid one), so long as the subpoena “appears valid on its face,” lacks “any indication of irregularity” that reasonably would put the defendant on notice that the subpoena is invalid, and the defendant does not actually know that the subpoena is invalid. Thus, whether a defendant satisfies this defense is a mixed question of fact and law, containing both objective and subjective elements. Finding that the subpoena bore all the indicia of lawful authority, and that there were no allegations that Yahoo! actually knew the subpoena was invalid, the court held that dismissal was proper, even if the subpoena was not.