Does a search warrant need to be obtained to obtain access to a user's e-mail address without a warrant?

¹³ Had the government itself engaged in this type of expansive review of user content (and in particular, a user's e-mails) without a warrant, there is little doubt it would be considered a search under the Fourth Amendment. (See United States v. Warshak (6th Cir. 2010) 631 F.3d 266, 285-286 [applying Fourth Amendment protection to e-mail contents]; see also Kyllo v. United States (2001) 533 U.S. 27, 40, 121 S.Ct. 2038, 150 L.Ed.2d 94 [concluding that the use of a thermal imaging technology constituted an unlawful search].)