There have been no court decisions indicating whether text messages and/or instant messages constitute a “public record” under West Virginia FOIA. However, depending on the specific circumstances, the holding of Associated Press v. Canterbury, supra. is likely to be instructive insofar as the Court in Associated Press. In that case, the Court recognized that e-mail communications fall within the scope of “writings” covered by the West Virginia FOIA. Text and instant messages are likely to be viewed in the same light.