Case 4 report

n re Matter of a Warrant to Search a Certain E-Mail Account Controlled and Maintained by Microsoft Corporation raises critical issues about the extraterritorial application of the warrant process under the Stored Communications Act. What is meant by the concept of extraterritorial application, how is that applied in the case of the Fourth Amendment (United States v Gorshkov), and how was the issue resolved in the Microsoft case? What alternatives exist for the acquisition of evidence that resides in a foreign country?