In a 2014 case, Microsoft challenged a federal search warrant for a customer's email records, on the ground that the data was stored on servers in a data center in Ireland and could not be produced to the U.S. authorities without an Irish warrant. The magistrate judge denied Microsoft's motion to quash the warrant, and following a hearing, Preska upheld the magistrate judge's ruling in a decision from the bench, holding that "It is a question of control, not a question of the location of that information." In 2016, the Second Circuit reversed on appeal, determining that the Stored Communications Act of 1986 did not apply extraterritorially. The case went to the Supreme Court, but was dismissed as moot due to Congress's enactment of the CLOUD Act in 2018, which created a process for U.S. investigators to access data stored overseas.