Case 1:20-mc-00036-JEB-DAR Document 10 Filed 08/18/20 Page 13 of 29 United States, 574 U.S. 528, 543 (2015) (“[W]e rely on the principle of noscitur a sociis—a word is known by the company it keeps—to avoid ascribing to one word a meaning so broad that it is inconsistent with its accompanying words, thus giving unintended breadth to the Acts of Congress.”); Humane Soc'y of the United States v. McCarthy, 209 F. Supp. 3d 280, 285 (D.D.C. 2016) (“[T]he cannons of statutory interpretation instruct courts to avoid construing the text of a statute to be contradictory; “our task is to fit, if possible, all parts into a harmonious whole.”). As stated previously, the definition of “person” specifically included United States government employees, agents, and political subdivisions, and implicitly excluded foreign government employees and agents. This strongly suggests that the term “entity” does not include governmental bodies, since if it did, there would have been no need for Congress to specifically include them in the definition of “persons.” Why do so if such governmental actors were already included within the definition of “entity”? Given that Congress clearly did not believe U.S. governmental bodies were “entities,” it would be extremely strange if it did want foreign governments and agents to fall within the definition of “entity.” This seems clear enough on its face, but to the extent there is any doubt, construing the term “entity” to exclude foreign governments would also conform to the canon of construction that disfavors an extraterritorial construction. See, e.g., Microsoft Corp. v. United States (In re Warrant to Search a Certain EMail Acct. Controlled & Maintained by Microsoft Corp., 829 F.3d 197, 218 (2d Cir. 2016), vacated and remanded sub nom. United States v. Microsoft Corp., 138 S. Ct. 1186 (2018) (“No relevant definition provided by either Title I or Title II of [the Electronic Communications Privacy Act] … suggests that Congress envisioned any extraterritorial use for the statute.”). Accordingly, under this reading, the plain language of the statute does not protect the privacy of the Myanmar government, its officials, or its agents. 7