We recently noted that Google had been ordered to comply with two FBI warrants seeking users’ data stored on servers located outside the United States in In re Search Warrant No. 16-960-M-1 to Google, No. 16-1061, 2017 WL 3535037 (E.D. Pa. Aug. 17, 2017). In a similar case, Matter of Search of Content Stored at Premises Controlled by Google Inc., Case No. 16-mc-80263-RS, 2017 WL 4700056 (N.D. Cal. Oct. 19, 2017), Google successfully moved for sanctions of $10,000 per day against itself for noncompliance with another warrant seeking data from offshore servers. By subjecting itself to such a sanctions order, Google sought standing to obtain appellate review of the court’s order compelling compliance. The government agreed that Google should be sanctioned for noncompliance, but also sought an evidentiary hearing on matters such as Google’s duty to preserve information pending appeal. The court denied the government’s request for an evidentiary hearing and imposed the $10,000-a-day sanction on Google.