1996). 3d 124 (1984). Apr. . Nov. 24, 1992); Goldstein v. ICC, No. 1985); Braintree Elec. 2d 21 (D.D.C.) Id. 2305(g) (2000), amended by Pub. To acquire a patent, full information about the method or product has to be supplied to the patent office and upon publication or issuance, will then be available to all. at 8-9 (D. Md. Va. 1993) (interpreting even less specific, pre-1998 version of unit price FAR provision to prohibit release of unit prices if such information "constitutes 'confidential business information'") (reverse FOIA suit). 8, 1993); Brown v. Dep't of Labor, No. at 1, 17 (D.D.C. 1985). 1986) (settlement negotiation documents reflecting "accounting and other internal procedures"); see also FOIA Update, Vol. (425), Similarly, in a case involving unexercised option prices rather than "ordinary" unit prices the court expressly stated that it "generally agrees that '[d]isclosure of prices charged the Government is a cost of doing business with the Government.'" for Auto Safety, 244 F.3d at 151-52 (finding that the district court had incorrectly equated the concept requiring release of information when "identical information" is already public, as a matter of exemption waiver, with the "customary treatment" standard, which allows Exemption 4 protection of voluntarily provided information if it "is of a kind that would customarily not be released to the public"). (263) The executive order requires that agencies give careful consideration to the submitters' objections and provide them with a written statement explaining why any such objections are not sustained. 92-Z-2101, transcript at 6 (D. Colo. Nov. 10, 1993) (bench order) (reverse FOIA suit). The tribunal can grant remedies in favour of complainants and order disciplinary action against persons who take reprisals. Citizen, 704 F.2d at 1286)). Exemption 4 of the FOIA protects "trade secrets and commercial or financial information obtained from a person [that is] privileged or confidential." 95-6140, slip op. 2.1 Applicable Law: Please cite any Applicable Laws in your jurisdiction applicable to cybersecurity, including laws applicable to the monitoring, detection, prevention, mitigation and management of Incidents.This may include, for example, data protection and e-privacy laws, intellectual property laws, confidentiality laws, information security laws, and import/export Also known as an exclusivity clause, this provision aims to prevent an employee from using insider knowledge to compete for business with their employer. 299. In the first decision to touch on this point, the court considered a situation in which the requester did not actually seek unit prices, but instead had requested the bottom-line price (total cumulative price) that an unsuccessful offeror had proposed for a government contract, as well as the bottom-line prices it had proposed for four years' worth of contract options. Oct. 6, 1999), dismissed as moot on motion for entry of judgment, 102 F. Supp. at 8 n.3 (D.D.C. Order No. Indeed, virtually every court that has considered the issue has found the Trade Secrets Act and Exemption 4 to be "coextensive." 89-2481, 1989 WL 550581, at *1 (D.D.C. To be considered a whistleblower in the United States, most federal whistleblower statutes require that federal employees have reason to believe their employer violated some law, rule, or regulation; testify or commence a legal proceeding on the legally protected matter; or refuse to violate the law. (353) This holding was affirmed by the Court of Appeals for the Second Circuit, which reiterated that "[t]he fact that [the] harm would result from active hindrance by the [requester] rather than directly by potential competitors does not affect the fairness considerations that underlie Exemption Four." Sept. 30, 1998) ("capital situation, [company's] assets, cash flow, investments, leverage ratios, 'cross-selling strategy,' pre-tax earnings by product line, dividend capacity, revenues, and rate changes for its insurance operations"), aff'd, 182 F.3d 900 (2d Cir. (173)), Two years after the decision in Critical Mass, a case involving government contract prices reached the D.C. . 1992); see also FOIA Update, Vol. at 15-16 (C.D. An NDA can help safeguard business assets, including but not limited to, the following: Chemical, mechanical and manufacturing processes are commonly protected under nondisclosure agreements. Mar. 343. Mar. Sept. 17, 1996); Sperry Univac Div. Jan. 19, 1988) (information contained in letters from contractor to agency regarding performance of contract that did not reveal contractor's suppliers or costs) (reverse FOIA suit); EHE Nat'l Health Serv. TRIFID Corp. v. Nat'l Imagery & Mapping Agency, 10 F. Supp. Appx. A customer list that requires more effort is more likely to be protected under an NDA. v. Baldrige, 3 Gov't Disclosure Serv. "Trump Team Promises To 'Dismantle' Dodd-Frank Bank Regulations". When should I use a Confidentiality Agreement? 1992). 195. (208) Similarly, the standard was found satisfied by the attestations made by submitters that described the limited distribution within the company on a "need to know" basis and attached as exhibits the confidentiality agreements that were entered into with outside contractors. Gov't Accountability, 1993 WL 13033518, at *1. 260. 706 (2000)); cf. The Court of Appeal of England and Wales in the case of Saltman Engineering Co Ltd v. Campbell Engineering Ltd[22] held that the action for breach of confidence is based on a principle of preserving "good faith". Va. Sept. 10, 1992) (accepting argument that disclosure of detailed unit price information would reveal pricing strategy and permit future bids to be predicted and undercut). 451, 454 (S.D.N.Y. Id. 2000); Martin Marietta Corp. v. Dalton, 974 F. Supp. Apr. 194. 92-2780, slip op. Circuit in the Washington Post case. Allnet Communications Servs. The Coca-Cola company, for example, has no patent for the formula of Coca-Cola and has been effective in protecting it for many more years than the 20 years of protection that a patent would have provided. Tex. See generally Flammann, 339 F.3d at 1323 (holding, in a pre-award bid protest case concerning unit prices contained in sealed bids -- as distinct from prices contained in proposals -- which were subject to the public opening requirement contained in a different FAR provision, that such bid prices "entered the public domain upon bid opening and therefore. An official website of the United States government. Group, Inc. v. United States Dep't of the Air Force, No. See, e.g., Dow Jones Co. v. FERC, 219 F.R.D. v. FCC, 800 F. Supp. 92-5351 (D.C. Cir. 1997) (no impairment from release of contract price information, because "[g]overnment contracting involves millions of dollars and it is unlikely that release of this information will cause [agency] difficulty in obtaining future bids") (reverse FOIA suit), rev'd on other grounds, 180 F.3d 303 (D.C. Cir. at 1 (D.D.C. 88-0481, 1989 WL 201031, at *3 (D.D.C. for Auto Safety v. Nat'l Highway Traffic Safety Admin., 244 F.3d 144, 147 (D.C. Cir. But, of course, the interviewees you dont hire wont be signing an employment NDA or employment agreement. MCI Worldcom, 163 F. Supp. (47) Similarly, the District Court for the District of Columbia has held that the fact that particular information is "arrived at through negotiation" with the government does not preclude it from being regarded as "obtained from a person." (159), In the fifth decision, the court held that although the D.C. 395. for Pub. 1:97-CV-252, slip op. Judicial Watch, Inc. v. United States Dep't of Energy, No. Other formulas that could be protected as trade secrets include pharmaceutical, chemical and cosmetic compounds. 97-5461, slip op. 365. or of any potential negative consequences disclosure may have for the public,. 2003) (dicta) (business and marketing plans "would" be exempt) (non-FOIA case brought under Administrative Procedure Act). While Douglas did not deny the role of these factors in production, he considered the Cultural heritage as the primary factor. However, this has not yet been established as law. McDonnell Douglas, 895 F. Supp. (457) The court readily held that in such a situation "[t]here can be no doubt" that disclosure would cause "substantial commercial harm," (458) because if the "technology is freely available on the Internet, there is no reason for anyone to license [it] from [its owner], and the value of [the owner's] copyright effectively will have been reduced to zero." Va. Sept. 10, 1992) (bench order) (same). at 6) (reverse FOIA suit), vacated as moot, No. 2004) (quoting agency declaration). for Auto Safety, 93 F. Supp. ; see Animal Legal Def. 552 note (2000), and in FOIA Update, Vol. See FOIA Update, Vol. 2d 23, 48-49 (D.D.C. 1993) (finding, based upon this holding in Critical Mass, that there was "nothing" it could do, "however much it might be inclined to do so," to upset agency regulations that permitted regulated entities to keep documents "on-site," outside possession of agency, and thus unreachable under FOIA) (non-FOIA case brought under Administrative Procedure Act), vacated for lack of standing sub nom. Headings are inserted for the convenience of the parties only and are not to be considered when interpreting this Agreement. See Hercules, Inc. v. Marsh, 839 F.2d 1027, 1030 (4th Cir. Corruption is a form of dishonesty or a criminal offense which is undertaken by a person or an organization which is entrusted in a position of authority, in order to acquire illicit benefits or abuse power for one's personal gain. (414) One of the cases was remanded back to the agency for further factfinding on that issue, (415) but in the remaining three cases the competitive harm arguments were rejected outright by the court. (199) Finding that the records at issue in the case before it were required to be submitted by the terms of the agency's contract solicitation, the Ninth Circuit declared that in light of that fact, it "need not address" the Critical Mass distinction. Citizen Health Research Group v. NIH, 209 F. Supp. XIV, No. ), Documents prepared by the government can still come within Exemption 4, however, if they simply contain summaries or reformulations of information supplied by a source outside the government, (45) or contain information obtained through a plant inspection. 2d 27 (D.D.C. 339. 2, at 1; FOIA Update, Vol. [11] See also: Natural resource economics, Exercise can be seen as individual factor of production, with an elastication larger than labor. [92] An amendment of article 362(1) adds articles 321abis to 321asepties to the list of provisions that may not be overruled by labour and bargaining agreements. (431) In rejecting the agency's competitive harm claim -- which was similar to the argument often made by submitters seeking to withhold unit prices, namely, that competitors could "reconstruct each factor in the bidder's calculations" by "comparing the total bid amount with information already in the public domain" -- the court relied on several of the district court decisions within the D.C. Download the Basic Non-Disclosure Agreement in Adobe PDF or Microsoft Word (.docx). (291) In this regard, a submitter's "admittedly weakened financial position" has been held "not [to] amount to a complete inability to suffer competitive harm," inasmuch as a "struggling, perhaps even failing, business remains entitled to the protections that Exemption Four affords to any company." Herman notes that her approach to her clinical experience grew out of her involvement in the civil rights movement. to a third party where the Employer has consented in writing to such disclosure; and. Circuit pointed out that agency disclosures of information that benefit competitors at the expense of submitters deserve "close attention" by the courts. Circuit expressly reserved the question of whether any other governmental interests -- such as compliance or program effectiveness -- might also be embodied in a "third prong" of the exemption. 1987) (finding that safety reports submitted by the nonprofit Institute for Nuclear Power Operations were "commercial," because the Institute's "'constituent utility companies [were] assuredly commercial enterprises engaged in the production and sale of electrical power for profit'" and "the commercial fortunes of" those "member utilities. 312. In earlier years, courts based the application of Exemption 4 upon whether there was a promise of confidentiality by the government to the submitting party, (49) or whether the information was of the type not customarily released to the public by the submitter. To tell or not to tell: Current functioning of child sexual abuse survivors who disclosed their. McDonnell Douglas, 895 F. Supp. 2. Commentators starting with A. Arthur Schiller assert that trade secrets were protected under Roman law by a claim known as actio servi corrupti, interpreted as an "action for making a slave worse" (or an action for corrupting a servant). 1994); Gulf & W. Indus. This Agreement may only be amended or modified by a written instrument executed by both the Employer and the Employee. 27. Dec. 31, 1992) (no impairment based on the speculative assertion that the public disclosure of Dun & Bradstreet reports will adversely affect a company's profits and thus make it "unlikely" that credit agencies will do business with the government; this "intimation regarding impairment of profits in no way speaks to the ability of affected credit agencies to continue to exist and supply needed data"); Wiley Rein & Fielding v. United States Dep't of Commerce, 782 F. Supp. As workers attempt to address concerns, they are often met with a wall of silence and hostility by management or colleagues. (448), In addition to the impairment prong and the competitive harm prong of the test for confidentiality established in National Parks & Conservation Ass'n v. Morton, the decision specifically left open the possibility of a third prong that would protect other governmental interests, such as compliance and program effectiveness. 92-5342 (D.C. Cir. A 1992 survey studying father-daughter incest in Finland reported that of the 9,000 15-year-old high school girls who filled out the questionnaires, of the girls living with their biological fathers, 0.2% reported father-daughter incest experiences; of the girls living with a stepfather, 3.7% reported sexual experiences with him. The best-known types are copyrights, patents, trademarks, and trade secrets.The modern concept of intellectual property developed in England in the 17th and 18th centuries. LEXIS 17194, at *2 (S.D. However, legal actions are costly and time-consuming. (190) The court first noted that the decision in Critical Mass provided it with "little guidance" as those documents "had been produced voluntarily by the originator, without any intervening espionage." at 12 n.10 (D. Or. The third requirement of Exemption 4 is met if information is "privileged or confidential." [29] The DTSA provides for both a private right of action for damages and injunction and a civil action for injunction brought by the Attorney General.[30]. 1984) (reverse FOIA suit). They will not be able to share the things they see on their tour. 1990) (striking original declaration of submitter "on basic fairness grounds," and then finding submitter "not able to support its position"), appeal dismissed voluntarily, No. The lack of formal protection associated with registered intellectual property rights, however, means that a third party not bound by a signed agreement is not prevented from independently duplicating and using the secret information once it is discovered, such as through reverse engineering. Order No. 2004) (Indian tribes (citing Indian Law Res. 767, 771 (D. Or. Citizen Health Research Group v. FDA, 704 F.2d 1280, 1290 (D.C. Cir. 331. 830 F.2d 278, 282, 286 (D.C. Cir. 510, 517 n.8 (E.D. Nation. 1974). Often, those who commit insurance fraud view it as a low-risk, lucrative enterprise. 81-1087, slip op. Bank, 108 F. Supp. The Employee is currently or may be employed as an employee with the Employer for the position of: __________. Id. The Employee agrees and acknowledges that the Confidential Information is of a proprietary and confidential nature and that any failure to maintain the confidentiality of the Confidential Information in breach of this Agreement cannot be reasonably or adequately compensated for in money damages and would cause irreparable injury to the Employer. (327) In that case, the D.C. Id. See CNA Fin. 931 F.2d 939, 948 (D.C. 11, 1994) (ruling on different FAR disclosure provision, and holding that that provision served as legal authorization for agency to release exercised option prices and that such prices thus were "not protected from disclosure by the Trade Secrets Act," 18 U.S.C. "Watch Thy Neighbor". v. HHS, 656 F. Supp. Its revenues are about 15 percent from Russian companies Circuit reversed the lower court on this point, but that decision was itself vacated when the D.C. Finally, the National Abuse Coalition was created in 1979 to create pressure in congress to create more sexual abuse laws. A list that is readily ascertainable cannot be protected. Allnet, No. 88-0631, 1989 WL 168858, at *3 (D.D.C. 1974). . Labor-power might be seen as a stock which can produce a flow of labor. (18) The Second Circuit declared that such an "interpretation [would give] much too narrow a construction to the phrase in question." Waste Mgmt., Inc. v. O'Leary, No. But cf. (160) In so holding, the district court again noted that "[w]hether to compete for [the agency's] business at all was, of course, [the submitter's] option, but having elected to do so it was required to submit the information [the agency] insisted on having if it hoped to win the contract." It guaranteed the right of federal employees to furnish information to the United States Congress. numbers of the inert ingredients" contained in pesticide formulas). Dec. 4, 1980). 185 F.3d at 903 (quoting requester's brief). Circuit rejected that argument and held that the scope of the Trade Secrets Act is "at least co-extensive with that of Exemption 4." Trade Secret Any formula, pattern, device or compilation of information that is used in business, that is not generally known, and that gives the owner of the secret an opportunity to obtain an advantage over competitors who do not know or use it. (157) Declaring that "no one disputes that the process of offer and acceptance giving rise to contractual obligations is voluntary," the court held that the "focal point" must be "the information itself" and that there was no question that the agency "required that the contract itemize the prices for specific services." However it is in response to such "duty speech" employee communication that the vast majority of retaliation against employees occurs. [75], Good government observers have hailed the EU directive as setting "the global standard for best practice rights protecting freedom of speech where it counts the mostchallenging abuses of power that betray the public trust," according to the U.S.-based Government Accountability Project. Indian Law Res. Fund, 44 F. Supp. (184) The court found that the rebate and incentive information at issue "may have made the bid more appealing or valuable to the government," but because it was not included within the list of items that the solicitation stated "must" be provided, it "was not required to be submitted within the meaning of Critical Mass." (488) By contrast, it concluded, recognition of a privilege for materials protected by a protective order under Rule 26(c)(7) "would be redundant and would substantially duplicate Exemption 4's explicit coverage of 'trade secrets and commercial or financial information.'" [22] Organizations also often attempt to ostracise and isolate whistleblowers by undermining their concerns by suggesting that these are groundless, carrying out inadequate investigations or by ignoring them altogether. In the Catholic sex abuse cases the various Roman Catholic Diocese in the United States have paid out approximately $1 billion settling hundreds of such lawsuits since the early 1990s. 158, 161 (S.D.N.Y. Id. Fund v. Mosbacher, No. Scissors Corp. v. GSA, No. 1982); Nat'l Parks & Conservation Ass'n v. Kleppe, 547 F.2d 673, 678 n.16 (D.C. Cir. 89. 4, 6 (D.D.C. (430) Nonetheless, the "cost of doing business" principle was again cited with approval by the District Court for the District of Columbia in an opinion issued two years ago that ordered disclosure of "the names of all entities that placed bids" to buy land that the government was selling, as well as "the amounts of all bids." (148), Significantly, the District Court for the District of Columbia has issued a total of seven decisions that all hold -- consistent with the Department of Justice's policy guidance on this issue -- that prices submitted in conjunction with a government contract are "required" submissions. 90. Va. June 7, 1996) (rejecting competitive harm argument, noting failure of agency even to give notice to submitters who, in turn, ultimately provided sworn declarations to requester explicitly stating that disclosure would not cause them harm); Wiley Rein & Fielding v. United States Dep't of Commerce, 782 F. Supp. [18][19][217] In the UK, a 2010 study estimated prevalence at about 5% for boys and 18% for girls[218] (not dissimilar to a 1985 study that estimated about 8% for boys and 12% for girls[219]). 43. (9), Trade secret protection has been recognized for product manufacturing and design information, (10) but has been denied for general information concerning a product's physical or performance characteristics or a product formula when release would not reveal the actual formula itself. Consequently, the total amount of available matter is fixed, and once all the available matter is used, nothing more can be produced without recycling or reusing matter from prior products. 92-289, 1993 WL 183736, at **7 & 8 n.3 (S.D.N.Y. 1999); Sokolow v. FDA, No. Circuit, the district court in Critical Mass found the requested information to be properly withheld pursuant to the third prong. Critical Mass, 975 F.2d at 878 (citing Wash. Post, 690 F.2d at 268-69); see Goldstein v. HHS, No. 410. See, e.g., Sterling Drug, Inc. v. FTC, 450 F.2d 698, 709 (D.C. Cir. XIII, No. (243) Because the case was remanded for further proceedings, the court found it unnecessary to decide the details of such a balancing test at that time. (105), In Center for Auto Safety the D.C. [1] Intellectual property law gives the owner of a trade secret the right to restrict others from disclosing it. 1981); accord CC Distribs., 1995 WL 405445, at *6; JL Assocs., 90-2 CPD 261, B-239790 at 4 (Oct. 1, 1990) (Comptroller General decision noting that "disclosure of prices charged the government is ordinarily a cost of doing business with the government"); see also EHE, No. [6][7] This research provides indirect evidence of the value of trade secrecy. . In Commonwealth common law jurisdictions, confidentiality and trade secrets are regarded as an equitable right rather than a property right.[21]. IV, No. (119) Using the same approach as the Department of Justice's Critical Mass guidance, the court specifically held that "[u]nder Critical Mass, submissions that are required to realize the benefits of a voluntary program are to be considered mandatory." Oct. 13, 1988); Pac. 2002). XVIII, No. Jan. 8, 1998); Afr. 92-0057-A, transcript at 27 (E.D. [53] Robert A. Larmer describes the standard view of whistleblowing in the Journal of Business Ethics by explaining that an employee possesses prima facie (based on the first impression; accepted as correct until proved otherwise) duties of loyalty and confidentiality to their employers and that whistleblowing cannot be justified except on the basis of a higher duty to the public good. (284) Rather than proceeding to a trial, the court in that case ordered that the document and a memorandum supporting its withholding be submitted to the court in camera. App. As a company can protect its confidential information through NDA, work-for-hire, and non-compete contracts with its stakeholders (within the constraints of employment law, including only restraint that is reasonable in geographic- and time-scope), these protective contractual measures effectively create a perpetual monopoly on secret information that does not expire as would a patent or copyright. ), vacated & reh'g en banc granted, 942 F.2d 799 (D.C. Cir. Id. 1989) (unpublished table decision); see, e.g., Inter Ocean Free Zone, 982 F. Supp. 495. However, several other actions may also be considered retaliatory, including extreme increases in workloads, having hours cut drastically, preventing task completion, or bullying. 1983). "), aff'd in part, rev'd in part & remanded on other grounds, 164 F.3d 37 (D.C. Cir. 738, 740 (N.D. Iowa 1974) (concluding that reports generated by commercial enterprise "must generally be considered commercial information"), rev'd on other grounds, 518 F.2d 1184 (8th Cir. 2001); Gilmore v. United States Dep't of Energy, 4 F. Supp. CV-97-273, slip op. Mar. Dec. 8, 1992) (deciding that the agency's "uncontradicted evidence . . 1985), rev'd on procedural grounds & remanded, 795 F.2d 205 (D.C. Cir. Marx considered the "elementary factors of the labor-process" or "productive forces" to be: The "subject of labor" refers to natural resources and raw materials, including land. (386) The court than analyzed each of the three categories of prices that were at issue in the case -- option prices, vendor prices, and "over and above" prices -- and found that the Air Force had "presented reasoned accounts of the effect of disclosure based on its experiences with government contracting." May 27, 1994). at 334 (finding also that EPA had not shown "that disclosure would jeopardize GE's commercial interests or reveal information about GE's ongoing operations, or that GE generated the information for a purpose other than advocating a policy to a governmental agency"); see also id. 1264, 1269 (D. Mass. An expression of consent is one that is unmistakably stated, rather than implied. where the employee has to anticipate dismissal, where the employee must assume that the competent authority will be hindered in investigating the irregularity, or. of Animals v. HHS, No. v. HHS, No. 1, at 2 (discussing statute and fact that key determinant of exempt status under it is whether proposal was incorporated into or otherwise set forth in resulting contract). AGS, No. 37, 39 (D.D.C. Mar. 1999). 435. The first step is often to issue a Cease and Desist Letter to remind the receiving party of their contractual obligations. See world news photos and videos at ABCNews.com 92-2720, slip op. Greenberg v. FDA, 803 F.2d 1213, 1215 (D.C. Cir. For sex crimes committed by minors, see, The examples and perspective in this section, Developing Mind, Daniel Siegel, Guilford Press, 1999, Arata, C. (1998). VI, No. Waiver. [the agency] would still be able to access the relevant information") (decided after Critical Mass, but by court that declined to apply it). at 202. This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply. 1986). Citizen, 704 F.2d at 1291 n.30 (observing that competitive harm should "'be limited to harm flowing from the affirmative use of proprietary information by competitors'" and "'should not be taken to mean'" harms such as "'customer or employee disgruntlement'" or "'embarrassing publicity attendant upon public revelations concerning, for example, illegal or unethical payments to government officials'" (quoting law review article)); Ctr. (304) In so deciding, the Ninth Circuit rejected the contention advanced by the submitting contractors that disclosure would allow their competitors to "undercut future bids," holding that their "rather conclusory statements" to that effect were insufficient as the data was "made up of too many fluctuating variables for competitors to gain any advantage from the disclosure." 139. NPR.org. 400, 402-03 (D.D.C. A temporary restraining order may be granted without notice to the infringer if it appears that immediate damage will result-for example, that evidence will be destroyed. The United States Supreme Court ruled that public sector whistleblowers are protected from retaliation by their First Amendment rights. (360) The Second Circuit also rejected the requester's argument that the Supreme Court's decision in United States Department of Justice v. Julian, (361) supported its contention "that confidentiality under Exemption 4 should be examined on a requester-specific basis," holding that because the requester was "not the party for whom the protections of Exemption 4 were intended, it ha[d] no claim of special access." App. where the employee is in a position to objectively demonstrate that a report to his employer will prove ineffective. Sept. 23, 1993) (reverse FOIA suit). Accordingly, the Employee will advise the Employer of the opportunity and cannot pursue the opportunity, directly or indirectly, without the written consent of the Employer. Often these entrepreneurs are seen as innovators, developing new ways to produce new products. 10-1103, 10-1275. to cause substantial harm to the competitive position of the person from whom the information was obtained." 352, 354-56 (D.D.C. (334) The question is whether "public disclosure" would cause harm; there is no "middle ground between disclosure and nondisclosure." 128. 2d 1217, 1222 (D. Mont. Bank, 108 F. Supp. (underlying FOIA request withdrawn after D.C. 2d 1188, 1195 (S.D. 2002) (information relating "'to business decisions and practices regarding the sale of power, and the operation and maintenance'" of generators (quoting agency declaration)); Merit Energy Co. v. United States Dep't of the Interior, 180 F. Supp. 2001); Gov't Accountability Project v. NRC, No.
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