Case 1:20-mc-00036-JEB-DAR Document 8 Filed 08/04/20 Page 13 of 18 of”—that is, the “intended message conveyed by the communication.” In re Zynga Privacy Litig., 750 F.3d 1098, 1106 (9th Cir. 2014). By its application, The Gambia asks this Court to grant it special and unbounded access to account information that no other governmental entity in the world—not even the United States—has available to it in any other proceeding.3 Indeed, the legal frameworks in place for disclosing certain content information in response to a request pursuant either to the international assistance processes established by U.S. law (e.g., MLAT), 18 U.S.C. § 3512, or the CLOUD Act’s exception to the SCA for foreign governments, 18 U.S.C. § 2702(b)(9), (c)(7), further demonstrate the inappropriateness of the Section 1782 application here. The international assistance process permits foreign governments to seek the assistance of the U.S. government, pursuant to a letter rogatory (or a mutual legal assistance treaty, if one existed). The U.S. government could then utilize 18 U.S.C. § 3512 to seek to obtain a search warrant from a U.S. court requiring the disclosure of content information to the U.S. government consistent with the SCA, which the U.S. government would then review and disclose to the foreign government. The CLOUD Act exception permits the disclosure of content information directly to a foreign government “pursuant to an order from a foreign government that is subject to an executive agreement that the Attorney General has determined and certified to Congress.” 18 U.S.C. § 2702(b)(9). Congress’s decision to create the CLOUD Act and codify international assistance 3 Facebook regularly cooperates with U.S. and foreign government requests for data that comply with relevant legal requirements, including those set forth in the SCA. As explained in Facebook’s Transparency Report, “[e]ach and every request we receive is carefully reviewed for legal sufficiency and we may reject or require greater specificity on requests that appear overly broad or vague.” See Government Requests for User Data, Facebook, https://transparency.facebook.com/government-data-requests (data showing Facebook received 140,875 government requests for data between July and December 2019, and produced some data in response to 74.4% of the requests). 9