Case 1:20-mc-00036-JEB-ZMF Document 22 Filed 09/22/21 Page 20 of 32 The privacy implications here are minimal given the narrow category of requested content. Content urging the murder of the Rohingya still permeates social media. See Stecklow, supra (documenting “more than 1,000 examples . . . of posts, comments, images and videos attacking the Rohingya or other Myanmar Muslims that were on Facebook” even after Facebook apologized for its services being “used to amplify hate or exacerbate harm against the Rohingya”). Such content, however vile, is protected by the SCA while it remains on the platform. The parade of horribles is limited to a single float: the loss of privacy protections for de-platformed content. And even that could be mitigated by users joining sites that do not de-platform content. The deleted content at issue here does not fall within electronic storage protected by the SCA. Exceptions To SCA Protection Irrespective of the above analysis, the SCA includes enumerated exceptions permitting disclosure of otherwise protected content. Most relevant here is the consent exception: “A provider . . . may divulge the contents of a communication . . . with the lawful consent of the originator . . . .” § 2702(b)(3). The Gambia also raises the provider protection exception: “A provider . . . may divulge the contents of a communication . . . as may be necessarily incident to the rendition of the service or to the protection of the rights or property of the provider of that service.” Id. § 2702(b)(5). Several district courts have held that disclosure under any SCA exception is purely voluntary on the part of the provider, relying on the term “may.” See, e.g., United States v. Wenk, 319 F. Supp. 3d 828, 829 (E.D. Va. 2017); PPG Indus., Inc. v. Jiangsu Tie Mao Glass Co., 273 F. Supp. 3d 558, 561 (W.D. Pa. 2017); In re Facebook, Inc., 923 F. Supp. 2d 1204, 1206 (N.D. Cal. 2012). This Court is not convinced. The California Supreme Court engaged in a more searching analysis: 20