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In the time that it takes you to read this sentence, more than 11 million new emails will have been sent worldwide.1 Email is just one of the many forms of electronic communication in the 21st century. The advent of the Internet transformed our society and enabled a world of hyperconnectivity and instant communication with each other, as well as seemingly limitless access to information. The often-ignored reality of technological advances in electronic communication is that with each new development comes the increased potential for an invasion of privacy. Before the telegraph, the only way to intercept communication between individuals meant overhearing a conversation or somehow obtaining a physical letter.2 Then, it became possible to intercept the electrical signals sent by a telegraph to decipher the electronic communication.3 Later, with the invention of the telephone came more advanced wiretapping, specifically the ability to listen to conversations without any physical presence at either end of the conversation.4 Now with the popularity of

Extraterritorial Application of the Stored Communications Act: Why Microsoft Corp. v. United States Signals That Technology Has Surpassed the Law