As of 2012, there were 3.3 billion email accounts in the world and that number is expected to increase by six percent each year, amounting to approximately 4.3 billion accounts in 2016. In 2013, there were approximately 7.137 billion people in the world. This implies that approximately half of the people in the world are email account holders. A large number of these emails are stored overseas. For example, Microsoft, just one of the many companies that operate email servers, recently admitted that the data from more than one billion of its customers—including the data for over 20 million businesses—is stored on one-hundred servers in forty countries. This potentially subjects millions of customer email to the overreaching tentacles of the U.S. government without any Fourth Amendment protections.