Google’s scanning of email for child pornography is a private search. The DHS review of defendant’s emails wasn’t a significant expansion of the private search. United States v. Wilson, 2017 U.S. Dist. LEXIS 98432 (S.D. Cal. June 26, 2017):
SA Thompson’s viewing of the four child pornography attachments arguably expanded upon Google’s private search. At least one Google employee had previously viewed each of the four child pornography images Defendant uploaded to his account; however, an employee did not open the four file attachments after Google’s hashing technology tagged the four images as child pornography. Nevertheless, even assuming arguendo that SA Thompson’s viewing of the four images was an expansion of Google’s private search, it was not a significant expansion.