I wonder where the line is drawn? If you set up AWS CloudFront, does that count as third party? Or is this taking us back to colo / in-house data centers?
So far, the line that has been drawn by the courts is "is the IP address visible to a company subject to the CLOUD Act in the United States?" AWS CloudFront would meet that definition: Amazon is covered by the CLOUD Act, and the visitor's IP address is visible when using that service.