Yahoo! Inc., a digital media company, was served with a grand jury subpoena from a Georgia district attorney requiring the disclosure of any and all records regarding the identification of one of its users. Yahoo! complied, and the user brought a putative class action against Yahoo! claiming various statutory provisions, and because the information was produced before the deadline for compliance with the subpoena. The Ninth Circuit affirmed the district court’s dismissal of the action because the Stored Communications Act [SCA; 18 U.S.C. §§ 2701-2712] provides a complete defense to any civil or criminal action where the defendant can demonstrate it produced documents in good faith reliance on a grand jury subpoena. Sams v. Yahoo! Inc. (Ninth Cir.; April 15, 2013) (Case No. 11-16938).
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