"Google regularly transfers user data from one data center to another without the customer's knowledge. Such transfers do not interfere with the customer’s access or possessory interest in the user data. Even if the transfer interferes with the account owner's control over his information, this interference is de minimis [minimal] and temporary."

“The court suggests that bringing a file back to the United States is not a seizure because Google moves data around all the time and ‘this interference is de minimis and temporary’,” Professor Orin Kerr wrote in the Washington Post.

“I don't think that works. Google is a private company not regulated by the Fourth Amendment, so whether it moves around data is irrelevant. And I don't see what is 'de minimis and temporary' about the government ordering Google to make a copy of your email pursuant to a court order.”