Given that 'the g00g' is delivering email in accordance with the very same NSLs I'm not sure how that's really better though. I would certainly place more faith in Google to properly maintain the security and configuration of an email server than myself.

The one advantage I see is that someone has to write the NSL in the first place so if you use a hosting provider that is very small you'd probably avoid attention just due to prioritization of resources. But that would only last until enough other people become aware of that refuge for it to become visible on the NSA's radar...