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section] 2702 (2012) (barring ISPs' divulgement of digital account content while such content held in their storage); see also Horton, supra note 30, at 569-70 (opining SCA bars ISPs from voluntarily disclosing digital account content postmortem); Borden, supra note 29, at 414 (arguing purpose and effect of SCA acts as bulwark to broad digital inheritance).
In empowering account holders with extensive privacy protections that prohibit ISP divulgement of stored communications, the SCA attempts to resolve this disparity.
section] 2702(b)(3)(b) (2012) (allowing divulgement of stored electronic communication if originator provides lawful consent), with PEAC, supra note 98, [section] 3 (enabling disclosure of digital contents only upon sufficient indicia of account holder consent).