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In this note, we study optimal estimation design for sampled linear systems where the sensors measurements are transmitted to the estimator site via a generic digital communication network. Sensor measurements are subject to random delay or might even be completely lost. We show that the minimum error covariance estimator is time-varying, stochastic, and it does not converge to a steady state. Moreover, the architecture of this estimator is independent of the communication protocol and can be implemented using a finite memory buffer if the delivered packets have a finite maximum delay. We also present two alternative estimator architectures that are more computationally efficient and provide upper and lower bounds for the performance of the time-varying estimator. The stability of these estimators does not depend on packet delay but only on the overall packet loss probability. Finally, algorithms to compute critical packet loss probability and estimators performance in terms of their error covariance are given and applied to some numerical examples.