Cloud computing is still an emerging technology, but its use is
expanding at a blistering pace.7 In 2011, the United States Government
implemented a “Cloud First” policy, requiring that before federal agencies
make any new investments, they must evaluate cloud-computing
solutions—citing the “considerable benefits to efficiency, agility, or
innovation.” 8 As such, several government agencies have already
implemented cloud solutions,9 and many more are anticipated to do so in
the coming years.10 Despite this mandate and rush to cloud computing,
some policy makers, law enforcement, and forensic investigators do not
appear to understand the nuances to investigating incidents and crimes in
the cloud, nor do they fully appreciate the implications in civil discovery.
Private companies are similarly rushing to cloud computing at a blistering