A recent Northern District of California decision has restricted the right of litigants to obtain certain information from third-party email service providers. The Stored Communications Act (SCA) prohibits a service provider from knowingly disclosing the contents of a wire, oral, or electronic communication, which is defined as “any information concerning the substance, purport, or meaning of that communication.” In Optiver Australia Pty. Ltd. & Anor. v. Tibra Trading Pty. Ltd. & Ors., No. C 1280242 (N.D. Cal. Jan. 23, 2013), a trading firm sued several former employees in the Federal Court of Australia for allegedly copying its proprietary source code and using it to found a new company. Suspecting that many key emails were sent through Google email accounts, the firm filed for judicial assistance pursuant to 28 U.S.C. § 1782 (which authorizes the district courts to enforce discovery requests from foreign judicial proceedings) to serve a subpoena on Google for documents sufficient to identify the recipient(s), sender, subject, date sent, date received, date read, and date deleted of emails, email attachments, and instant messages during a specific time period from certain email addresses. The court partially granted a motion to quash the subpoena to Google because it held that the subject lines of emails and seeking information about emails containing certain terms would constitute “content” under the SCA.