In In re Search Warrant No. 16-960-M-01 to Google, Misc. No. 16-960-M-01 (E.D. Pa. Feb. 3, 2017), a Pennsylvania-based U.S. magistrate judge ordered Google to comply with two FBI search warrants, issued pursuant to Section 2703 of the Stored Communications Act (SCA), to produce emails stored on servers in Ireland. The court’s decision runs contrary to an earlier ruling of the U.S. Court of Appeals for the Second Circuit, which held that Microsoft was not required to produce emails stored in Ireland.  See Matter of Warrant to Search a Certain E-Mail Account Controlled & Maintained by Microsoft Corp., 829 F.3d 197 (2d Cir. 2016).  The court reasoned that “the conduct relevant to the SCA’s focus will occur in the United States” because the invasion of privacy will not occur until “the FBI reviews the copies of the requested data in Pennsylvania.”  By contrast, “[e]lectronically transferring data from a server in a foreign country to Google’s data center in California does not amount to a ‘seizure’ [under Fourth Amendment principles] because there is no meaningful interference with the account holder’s possessory interest in the user data.”  Accordingly, the court held that compelling production of the emails “involve[d] a permissible domestic application of the SCA, even if other conduct (the electronic transfer of data) occurs abroad.”