A recent privacy case in the US Court of Appeals for the Second Circuit suggests that the pendulum has swung toward recognition that national governments need to recognize the legitimacy of other countrys borders too. Microsoft challenged a court order that sought emails held on Microsoft servers in Ireland. The court went so far as to recognize that there is a presumption against extraterritorial application of US laws meaning that it is presumed that US laws should not be applied beyond US borders. By recognizing the jurisdictional boundaries of Ireland, it is possible that the court created an incentive for other jurisdictions to require data to be held within their national boundaries.”]