When employees use their personal cell, tablet, laptop, or PC it’s not so simple to determine who owns the content of their email and intellectual property. Notwithstanding the 2010 US Supreme Court 9-0 ruling (in the City of Ontario v Quon) that an employee who uses a company issued device is not entitled to constitutional privacy, when an employee conducts company business using their own personally owned device the question of ownership is much more complex.