Plaintiff demanded that Microsoft produce documents from the hotmail account of an Indian citizen imprisoned abroad. Suzlon Energy Ltd. v. Microsoft Corp., No. 10–35793 (9th Cir. Oct. 3, 2011). Microsoft objected to the production, and the district court agreed with Microsoft. The court found that the hotmail account-holder was entitled to the protection of the Electronic Communications Privacy Act (“ECPA”), even though he was a foreign citizen, and the Ninth Circuit affirmed. The appellate court found that the words “any person” in the statute included non-citizens, and also rejected plaintiff’s argument that the account-holder’s participation in the underlying lawsuit established an implied consent to the production of the hotmail documents.