"For its part, the Justice Department has taken a legalistic approach: a 17-page brief it filed last month acknowledges that federal law requires search warrants for messages in "electronic storage" that are less than 181 days old. But, Assistant U.S. Attorney Pegeen Rhyne writes in a government brief, the Yahoo Mail messages don't meet that definition.
"Previously opened e-mail is not in 'electronic storage,'" Rhyne wrote in a motion filed last month"
Am I missing something here? How is web-based email not in electronic storage? Where is it then?