In Corsair Special Situations Fund, L.P. v. Engineered Framing Systems, Inc., a federal court refused to quash a subpoena to Verizon Wireless for text messages on the ground that the cell-service subscriber who sent and received the messages had no reasonable expectation of privacy in the messages and therefore had no standing to challenge the subpoena. Apparently neither the subscriber’s lawyers nor the court had heard of ECPA, which clearly bars disclosure of the content of electronic communications in response to a civil subpoena. The danger for a small provider, or its new employees not yet fully trained, is that it may be lulled into thinking that, once a motion to quash is denied, it can disclose the messages. Wrong. The provider would still be violating ECPA if it discloses communications content in such a scenario. While “good faith” reliance on a subpoena or other lawful process is a defense against liability, a court might have trouble finding reliance to be in “good faith” where the process is clearly contrary to law.