On July 14, 2016, the Second Circuit handed Microsoft a victory when it held that the Stored Communications Act (SCA) does not authorize warrants against US-based service providers for content "stored exclusively on foreign servers." The dispute concerned a warrant application by the United States for the contents of a Microsoft customer's email account in connection with a narcotics trafficking investigation. Microsoft produced all information it held in the United States, as directed, but refused to produce data stored on the company's servers in Ireland. The Second Circuit rejected the government's argument that an SCA warrant requires records and other materials be produced "no matter where those documents are located, so long as they are subject to the recipient's custody or control." The Court explained that "[w]arrants traditionally carry territorial limitations"; therefore, warrants issued to seize items in the United States do not extend beyond the United States. Additionally, the Court stated that it was bound by the Supreme Court's recent rulings emphasizing the "presumption against extraterritoriality" for warrants.