No, the "no rights zone" only applies to non-USPERs outside of U.S. soil. NSA might reasonably be able to claim that they didn't know a given email address used outside the U.S. actually belongs to a U.S. person, but they'd have a much harder argument claiming that a phone issued to a U.S. area code didn't reasonably belong to a U.S. person, even if used overseas.