Ryan v. United States Department of Justice
CourtDistrict Court, District of Columbia
Date FiledSeptember 11, 2026
DocketCivil Action No. 2023-3815
JudgeJudge Sparkle L. Sooknanan
StatusPublished
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Full Opinion
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
NAOISE CONNOLLY RYAN, et al.,
Plaintiffs,
Civil Action No. 23 - 3815 (SLS)
v. Judge Sparkle L. Sooknanan
DEPARTMENT OF JUSTICE,
Defendant.
MEMORANDUM OPINION
In October 2018, a Boeing 737 MAX aircraft crashed shortly after takeoff in Indonesia.
Less than six months later, another Boeing 737 MAX aircraft crashed in Ethiopia. Tragically, none
of the 346 people onboard the planes survived. After investigating the crashes, the Department of
Justice (DOJ) entered a deferred prosecution agreement with Boeing, which many of the victims’
families opposed. In 2022, 15 family representatives of the crash victims and their counsel
submitted a Freedom of Information Act (FOIA) request to DOJ’s Criminal Division. They
requested a range of records related to the aircraft crashes and subsequent investigations. Having
received no response for over a year, the Plaintiffs sued to compel DOJ to produce the requested
records. To efficiently move the case forward, the Parties agreed that DOJ would process a random
sample of a subset of the potentially responsive documents. DOJ withheld most of the documents
under FOIA Exemptions 3, 4, 6, 7(A), and 7(C). The Parties now cross-move for summary
judgment regarding the applicability of those exemptions. The Court grants in part and denies in
part both motions.
BACKGROUND
A. Statutory Background
“FOIA ‘implements a general philosophy of full agency disclosure.’” Informed Consent
Action Network (ICAN) v. NIH, No. 23-cv-926, 2026 WL 585104, at *1 (D.D.C. Mar. 3, 2026)
(quoting DOJ v. Reps. Comm. for Freedom of the Press, 489 U.S. 749, 754 (1989) (cleaned up)).
The statute “requires every federal agency, upon request, to make ‘promptly available to any
person’ any ‘records’ so long as the request ‘reasonably describes such records.’” Assassination
Archives & Rsch. Ctr. v. CIA, 334 F.3d 55, 57 (D.C. Cir. 2003) (quoting 5 U.S.C. § 552(a)(3)).
“Agencies must construe FOIA requests liberally and can only withhold or redact documents if
the information requested ‘falls within one of nine statutory exemptions.’” ICAN, 2026 WL
585104, at *1 (quoting People for the Ethical Treatment of Animals (PETA) v. NIH, 745 F.3d 535,
540 (D.C. Cir. 2014)); see 5 U.S.C. § 552(b)(1)–(9). “These exemptions demonstrate that the
public’s right to information is ‘not absolute and that disclosure of certain information may harm
legitimate governmental or private interests.’” Am. Ctr. for L. & Just. v. FBI, No. 22-cv-3711,
2026 WL 1585366, at *1 (D.D.C. June 3, 2026) (quoting Martin v. DOJ, 488 F.3d 446, 453 (D.C.
Cir. 2007) (quotations omitted). The agency bears the burden of establishing that an exemption
applies and ordinarily “must disclose all reasonably segregable, nonexempt portions of the
requested record(s).” PETA, 745 F.3d at 540 (cleaned up).
B. Factual and Procedural Background
The Court draws the facts from the Defendant’s Statement of Material Facts and the
underlying materials referenced in that statement. See Def.’s Statement of Undisputed Facts
(DSOF), ECF No. 35–1. The Court assumes the facts in that statement to be true unless they have
2
been specifically disputed, and it assumes the truth of other undisputed statements in the record.
See Fed. R. Civ. P. 56(e)(2); see also LCvR 7(h)(1).1
In October 2018, a Boeing 737 MAX crashed in Indonesia, killing 189 people. Compl. ¶ 2,
ECF No. 1. Five months later, another Boeing 737 MAX crashed in Ethiopia, killing 157 people.
Id. DOJ then criminally investigated Boeing and reached a deferred prosecution agreement with
the company in January 2021. See United States v. Boeing Co., 655 F. Supp. 3d 519, 524–26 (N.D.
Tex. 2023) (explaining the case’s timeline). Three years later, the government revoked the Boeing
deferred prosecution agreement after breaches by Boeing, before executing a new non-prosecution
agreement. See United States v. Boeing Co., No. 4:21-CR-5, 2025 WL 3095958, at *1 (N.D. Tex.
Nov. 6, 2025) (providing further context); Herrington Decl. ¶ 31–34, ECF No. 35-2 (describing
the terms of the agreement).
The Plaintiffs in this case are 15 family representatives of the crash victims and their
counsel. Compl. ¶ 11–26. In 2022, the Plaintiffs submitted a FOIA request to DOJ’s Criminal
Division requesting a range of records related to the aircraft crashes and subsequent investigations.
ECF No. 1-1. The Plaintiffs filed this case in December 2023, alleging that DOJ had failed to
produce documents responsive to their request. Compl. ¶¶ 71–87.
1
Here, neither party filed a separate statement in opposing the respective motions. See Def.’s Resp.
and Cross-Mot. Summ. J. (Cross-Mot.), ECF No. 35; Pls.’ Reply, ECF No. 38. In part, this is
because the Parties dispute whether the Plaintiffs’ self-titled “Statement of Facts” included in their
Motion for Summary Judgment, Pls.’ Mot. Summ. J., ECF No. 34, satisfies the requirement that
“[e]ach motion for summary judgment shall be accompanied by a statement of material facts as to
which the moving party contends there is no genuine issue[.]” LCvR 7(h)(1). Regardless, Local
Rule 7(h) provides that “the Court may assume that facts identified by the moving party in its
statement of material facts are admitted, unless such a fact is controverted in the statement of
genuine issues filed in opposition to the motion.” LCvR 7(h)(1). Accordingly, the Court will
reference the Defendant’s Statement of Undisputed Facts. Further, when the Plaintiffs’ factual
assertions are not covered in the Defendant’s Statement but supported by record evidence, the
Court will accept them as uncontroverted. See Hinson ex rel. N.H. v. Merritt Educ. Ctr., 579
F. Supp. 2d 89, 92 n.2 (D.D.C. 2008).
3
The Plaintiffs eventually narrowed their request. See Joint Status Report ¶ 4, ECF No. 24.
Specifically, the Plaintiffs now seek records related to conversations between Boeing and DOJ
about the criminal investigation, subsequent negotiations between DOJ and Boeing, and the
Boeing deferred prosecution agreement that the Plaintiffs opposed. See ECF No. 24; Compl.
¶¶ 55–65. In February 2025, the Parties agreed that the Department would process an agreed-upon
random sample of 232 total responsive records. DSOF ¶ 5–6. Of the 232 total records, 46 records
were responsive to the narrowed scope of the Plaintiffs’ request. Herrington Decl. ¶ 8, ECF No. 35-
2. Of that subset, the Department released 150 pages to the Plaintiffs in part. DSOF ¶ 10. The
Department withheld 36 records (comprising 1,597 pages) in full. DSOF ¶ 11.
The current dispute focuses on the applicability of certain FOIA exemptions to those
withholdings.2 Of the pages released in part, DOJ invoked Exemptions 6 and 7(C) to redact privacy
information, DSOF ¶ 17–19, and Exemption 4 to redact confidential commercial information,
DSOF ¶ 14–16. In addition to its partial withholdings, DOJ invoked multiple overlapping
exemptions to withhold 36 records in full. First, the Department withheld 30 records in full
pursuant to Exemption 3, alleging that they consist of grand jury materials. DSOF ¶ 12. They also
alleged that these documents were exempt, either in full or in part, under Exemptions 4 (for
containing confidential commercial information) and 7(A) (for containing information compiled
2
Because of a disagreement over the Vaughn indices, the Parties’ accounting of the withheld
records varies. Throughout its cross-motion, DOJ repeatedly faults the Plaintiffs for attaching a
“draft” Vaughn index to their motion for summary judgment, alleging that it provided this draft to
the Plaintiffs only in the context of settlement negotiations. E.g., Cross-Mot. 4–6. Therefore, DOJ
attached its own “final” Vaughn index to its cross-motion, which covers only records withheld in
full. ECF 35–2. Given the history of this case, DOJ’s complaints have no force and border on bad
faith. At status conferences before this Court, DOJ agreed to provide a draft Vaughn index
precisely so that the Plaintiffs could move for summary judgment. Indeed, the Parties agreed that
the Plaintiffs would move first, and it would have been impossible to do so without a Vaughn
index. In any case, for the purpose of the pending motions, the Court discerns only minimal
differences between the “draft” and “final” Vaughn indices. ECF 35-2.
4
for law enforcement purposes). DSOF ¶ 20. Next, DOJ withheld the remaining six documents in
full, also pursuant to Exemptions 4 and 7(A). DSOF ¶ 14; Herrington Decl. ¶ 9. Additionally, DOJ
withheld one document (Document 4) in full pursuant to Exemptions 6 and 7(C) because it
contained the personnel file of a Boeing employee.3 DSOF ¶ 17. Finally, DOJ asserted that all 36
of the records withheld in full had underlying redactions under Exemptions 6 and 7(C) because
they contained employees’ personal identifying information. DSOF ¶ 18.
In May 2026, the Plaintiffs moved for summary judgment challenging DOJ’s invocation
of FOIA Exemptions 3, 4, 6, 7(A), and 7(C). Pls.’ Mot. Summ. J., ECF No. 34. The Department
then cross-moved for summary judgment. Def.’s Resp. and Cross-Mot. Summ. J., (Cross-Mot.),
ECF No. 35. Both motions are now ripe for review. See Pls.’ Reply, ECF No. 38.4
LEGAL STANDARD
Federal Rule of Civil Procedure 56 requires a court to “grant summary judgment if the
movant shows that there is no genuine dispute as to any material fact and the movant is entitled to
judgment as a matter of law.” Fed. R. Civ. P. 56(a). In a FOIA suit, an agency is entitled to
summary judgment if it establishes that “no material facts are in dispute” and that all information
subject to a request has either “been produced or is wholly exempt from the Act’s inspection
requirements.” Students Against Genocide v. Dep’t of State, 257 F.3d 828, 833 (D.C. Cir. 2001)
(quoting Goland v. CIA, 607 F.3d 339, 352 (D.C. Cir. 1978)). Typically, an “agency demonstrates
the applicability of a FOIA exemption by providing affidavits regarding the claimed exemptions.”
3
The “draft” Vaughn index also indicates that Document 11 was withheld in full pursuant to
Exemptions 6 and 7(C). ECF 34–6. However, as DOJ explains, Document 11 is duplicative of
Document 4 and was therefore removed from the “final” Vaughn index. Cross-Mot. 6 n.3;
Herrington Decl. ¶ 8. The Plaintiffs do not seem to challenge this account. See Reply, ECF No. 38.
4
Even though it cross-moved for summary judgment when opposing the Plaintiffs’ motion, DOJ
opted not to file a reply brief responding to the Plaintiffs’ last brief.
5
Shapiro v. DOJ, 893 F.3d 796, 799 (D.C. Cir. 2018). “If an agency’s affidavit describes the
justifications for withholding the information with specific detail, demonstrates that the
information withheld logically falls within the claimed exemption, and is not contradicted by
contrary evidence in the record or by evidence of the agency’s bad faith, then summary judgment
is warranted on the basis of the affidavit alone.” ACLU v. U.S. Dep’t of Def., 628 F.3d 612, 619
(D.C. Cir. 2011). “[A]n agency’s justification for invoking a FOIA exemption is sufficient if it
appears ‘logical’ or ‘plausible.’” Wolf v. CIA, 473 F.3d 370, 374–75 (D.C. Cir. 2007) (quoting
Gardels v. CIA, 689 F.2d 1100, 1105 (D.C. Cir. 1982)).
DISCUSSION
The Parties contest the applicability of FOIA Exemptions 3, 4, 6, 7(A), and 7(C) to an
overlapping array of records. The Court considers the application of each exemption in turn.5
A. Exemption 3
DOJ invoked Exemption 3 to withhold three categories of documents: (1) grand jury
subpoenas, (2) responses to those subpoenas, and (3) other records intended to demonstrate
Boeing’s legal compliance. Cross-Mot. 5–6; Herrington Decl. ¶ 15. The Plaintiffs argue that DOJ
has not met its burden of demonstrating that these records are exempt. Reply 4–6. The Court finds
that some—but not all—of these records were properly withheld.
Exemption 3 permits the government to withhold records that are “specifically exempted
from disclosure by statute.” 5 U.S.C. § 552(b)(3). Here, DOJ points to Federal Rule of Criminal
5
DOJ contends that “the adequacy of [its] search is not at issue in this litigation and judgment on
that issue should be granted to [DOJ].” Cross-Mot. 3. This argument entirely ignores the
procedural posture of this case. This case is almost three years old. The Parties spent years
discussing search parameters and narrowing—ultimately agreeing that DOJ would pull and
process a random sample of responsive records and provide a Vaughn index so that the Parties
could preliminarily litigate exemptions to move this case forward. The instant summary judgment
proceedings are solely about that.
6
Procedure 6(e) as the relevant statute, which prohibits disclosure of certain “matters occurring
before [a] grand jury.” Fed. R. Crim. P. 6(e). The D.C. Circuit has confirmed that Rule 6(e) “counts
as a statute for the purposes of Exemption 3[.]” Sussman v. U.S. Marshals Serv., 494 F.3d 1106,
1113 (D.C. Cir. 2007). As a result, certain grand jury materials may not be disclosed even in
response to an otherwise valid FOIA request. See Fund for Const. Gov’t v. Nat’l Archives &
Records Serv., 656 F.2d 856, 867–68 (D.C. Cir. 1981). That said, Rule 6(e) does not “draw ‘a veil
of secrecy . . . over all matters occurring in the world that happen to be investigated by a grand
jury.’” Senate of P.R. v. DOJ, 823 F.2d 574, 582 (D.C. Cir. 1987) (quoting SEC v. Dresser Indus.
Inc., 628 F.2d 1368, 1382 (D.C. Cir. 1980) (en banc)). Put differently, “[t]here is no per se rule
against disclosure of any and all information which has reached the grand jury chambers[.]” Senate
of P.R., 823 F.2d at 582. Rather, the question is whether disclosure would “tend to reveal some
secret aspect of the grand jury’s investigation, such matters as the identities of witnesses or jurors,
the substance of testimony, the strategy or direction of the investigation, the deliberations or
questions of jurors, and the like.” Id.
In this case, DOJ invoked Rule 6(e) to exempt “grand jury subpoenas for documents or
testimony or responses to those subpoenas, including the production of records by Boeing.”
Herrington Decl. ¶ 15. They also withheld other records, such as presentations by Boeing “to
demonstrate compliance with federal law to prevent indictment.” Id. DOJ argues that this
information would “shed light upon how the grand jury went about its work” and “reveal
information concerning strategies behind the grand jury investigation.” Cross-Mot. 5 (quotations
omitted). Therefore, the Court considers the application of Rule 6(e) to three categories of records:
(1) grand jury subpoenas, (2) responses to those subpoenas, and (3) other records intended to
demonstrate legal compliance. See Lopez v. DOJ, 393 F.3d 1345, 1349 (D.C. Cir. 2005)
7
(encouraging a categorical approach to the Exemption 3 analysis and explaining that courts “need
not evaluate the revelatory characteristics of every individual document in each case before it”).
First, DOJ withheld grand jury subpoenas for documents or testimony. The Court agrees
that DOJ properly withheld these records. The D.C. Circuit has categorically stated that “[a]ll
grand jury subpoenas (be they ad testificandum or duces tecum) . . . fall within FOIA’s third
exemption.” Id. at 1350. The Plaintiffs do not seriously contest this. Reply 4–6 (focusing on
whether DOJ has demonstrated that all the withheld material would undermine grand jury secrecy).
Second, DOJ claims Exemption 3 coverage over certain responses to grand jury subpoenas.
But on this record, DOJ may not withhold those documents. As the D.C. Circuit has explained,
“[t]he mere fact the documents were subpoenaed fails to justify withholding under Rule 6(e).”
Labow v. DOJ, 831 F.3d 523, 530 (D.C. Cir. 2016). This is because “[t]he disclosure of information
‘coincidentally before the grand jury [which can] be revealed in such a manner that its revelation
would not elucidate the inner workings of the grand jury’ is not prohibited.” Senate of P.R., 823
F.2d at 582 (quoting Fund for Const. Gov’t, 656 F.2d at 870). Here, the government offers only
that disclosure “could reveal information concerning strategies behind the grand jury
investigation.” Herrington Decl. ¶ 16. But without more, this conclusory statement is insufficient.
See Labow, 831 F.3d at 530 (criticizing a similarly conclusory statement in a government
declaration); Senate of P.R., 823 F.2d at 584 (requiring “some affirmative demonstration of a
nexus between disclosure and revelation of a protected aspect of the grand jury’s investigation”).
In fact, DOJ admits that it never undertook a line-by-line review of these documents, marking
them as exempt simply because they were “collected and/or utilized for purposes of a grand jury
proceeding.” Herrington Decl. ¶ 38. The Department may not broadly withhold documents solely
because they were somehow related to a grand jury proceeding. See Bagwell v. DOJ, No. 15-cv-
8
00531, 2015 WL 9272836, at *4 (D.D.C. Dec. 18, 2015) (explaining that unless the government
makes an affirmative demonstration, it “cannot rely on Exemption (b)(3) to shield from disclosure
everything it considers to be in some way ‘related’ to the grand jury’s proceedings”).
To be clear, responses to grand jury subpoenas may properly be withheld held under
Exemption 3. For example, responses could reveal the contents of the subpoena itself, see Lopez,
393 F.3d at 1350, or include protected information such as the “identities of witnesses or jurors,”
Dresser, 628 F.2d at 1382. But DOJ entirely fails to “suppl[y] the information a court must have
in order to intelligently make that judgment.” Senate of P.R., 823 F.2d at 584. And almost three
years into this case, when processing only a small sample of documents to enable the Court to
narrow the disputes between the Parties, DOJ’s decision to proceed in this manner is disappointing.
Third, DOJ seeks to broadly shield other records, including Boeing’s presentations and
communications intended to demonstrate its compliance with federal law or the Boeing deferred
prosecution agreement. Once again, DOJ has not shown how these documents would tend to
“elucidate the inner workings of the grand jury[.]” Senate of P.R., 823 F.2d at 582. As the D.C.
Circuit has emphasized in a similar case, it is “necessary to differentiate between statements by a
prosecutor’s office with respect to its own investigation, and statements by a prosecutor’s office
with respect to a grand jury’s investigation[.]” In re Sealed Case No. 99-3091, 192 F.3d 995, 1002
(D.C. Cir. 1999); see also In re Grand Jury Subpoena, 920 F.2d 235, 242 (4th Cir. 1990)
(“[I]nformation produced by criminal investigations paralleling grand jury investigations does not
constitute matters ‘occurring before the grand jury’ if the parallel investigation was truly
independent of the grand jury proceedings.”). Boeing’s compliance with federal law and the
deferred prosecution agreement may have implications for DOJ’s independent investigation, but
DOJ never attempts to show why it would “tend to reveal some secret aspect of the grand jury’s
9
investigation[.]” Senate of P.R., 823 F.2d at 582. Indeed, this is particularly unlikely given that the
Plaintiffs seek this information “for its intrinsic value in furtherance of a lawful investigation,”
instead of “to learn what took place before the grand jury.” Boehm v. FBI, 983 F. Supp. 2d 154,
159 (D.D.C. 2013) (cleaned up).
In sum, DOJ properly invoked Exemption 3 in combination with Rule 6(e) to withhold
grand jury subpoenas for documents or testimony. However, it falls well short of its burden to
show that the responses to those subpoenas or Boeing’s other compliance communications were
appropriately withheld. Accordingly, the Court will grant in part and deny in part both motions as
to the records withheld under Exemption 3.6
B. Exemption 4
Next, the Department invoked Exemption 4 to withhold (1) information provided by
Boeing during the criminal investigation related to the company’s internal operations, compliance
programs, and business strategy, and (2) information of three other business entities that Boeing
had provided to DOJ as proposed administrators for the compensation fund. Herrington Decl.
¶ 17–18. The Plaintiffs argue that DOJ has not demonstrated that the withheld information is
commercial or confidential, or that reasonably foreseeable harm would result from disclosure. See
Mot. Summ. J. 13–14; Reply 6–8. The Court largely agrees with the Plaintiffs.
Exemption 4 shields from disclosure “trade secrets and commercial or financial
information obtained from a person and privileged or confidential.” 5 U.S.C. § 552(b)(4). For non-
trade-secret information, an agency must show that the information is “(1) commercial or financial,
(2) obtained from a person, and (3) privileged or confidential” to withhold it. Pub. Citizen Health
6
For records withheld under Exemption 3, DOJ need not prove that harm would foreseeably result
from disclosure. See 5 U.S.C. § 552(a)(8)(B).
10
Rsch. Grp. v. FDA, 704 F.2d 1280, 1290 (D.C. Cir. 1983). And the agency may only withhold the
information if it “reasonably foresees that disclosure would harm an interest protected by”
Exemption 4. See 5 U.S.C. § 552(a)(8)(A)(i)(I). No one disputes that the withheld records were
obtained from a person, so the Court focuses on the first and third requirements.
1. Commercial or Financial
The D.C. Circuit has “consistently held that the terms ‘commercial’ and ‘financial’ in the
exemption should be given their ordinary meanings.” Pub. Citizen, 704 F.2d at 1290. Therefore,
“information is commercial if it pertains to the exchange of goods or services or the making of a
profit.” Citizens for Resp. & Ethics in Washington (CREW) v. DOJ, 58 F.4th 1255, 1263 (D.C.
Cir. 2023). This often includes information that “actually reveal[s] basic commercial operations,
such as sales statistics, profits and losses, and inventories[.]” Pub. Citizen, 704 F.2d at 1290.
However, Exemption 4 does not protect information that “only tenuously or indirectly concerns
the exchange of goods or services or the making of a profit.” CREW, 58 F.4th at 1265.
Here, DOJ argues that Boeing had a commercial interest in information related to “the
company’s internal operations, compliance programs, and business strategy.” Cross-Mot. 8. For
example, some of the compliance presentations that Boeing submitted to DOJ “contained
information regarding the company’s business activities and resources.” Id. As DOJ’s declarant
explained, “Boeing has a commercial interest in the information related to their business activities,
as establishing and maintaining these activities requires a substantial dedication of company
resources.” Herrington Decl. ¶ 18.
Though bordering on conclusory, the Court finds this explanation sufficient. Business
strategies, activities, and resources are within the ambit of “commercial” or “financial” activities
as those terms are commonly understood. See Pub. Citizen, 704 F.2d at 1290. And courts in this
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District have made clear that “information about the way the companies implement their
compliance programs” can be “sufficiently ‘instrumental’ to [] companies’ operations to qualify
as commercial.’” 100Reporters LLC v. DOJ, 248 F. Supp. 3d 115, 137 (D.D.C. 2017) (cleaned
up). In addition, the three proposed third-party administrators likely had a similar commercial
interest in their own credentials and information.
The Plaintiffs make two arguments in response. First, they argue that after extensive
investigations and reporting, the commercial details in the records have likely already been
publicized. Mot. Summ. J. 13; Reply 7. On this point, the D.C. Circuit has indeed held “that the
government cannot rely on an otherwise valid exemption claim to justify withholding information
that has been ‘officially acknowledged’ or is in the ‘public domain.’” Davis v. DOJ, 968 F.2d
1276, 1279 (D.C. Cir. 1992) (quoting Afshar v. Dep’t of State, 702 F.2d 1125, 1130–34 (D.C. Cir.
1983)). However, “a plaintiff asserting a claim of prior disclosure must bear the initial burden of
pointing to specific information in the public domain that appears to duplicate that being withheld.”
Afshar, 702 F.2d at 1130 (emphasis added). The Plaintiffs here point to a handful of news articles
detailing the “financial strategies and technical details producing the plane crashes.” Mot. Summ.
J. 13; Reply 7. But beyond this speculation, they offer no specific information as to where in the
public domain the withheld information—such as Boeing’s compliance presentations—may be
found. Therefore, their argument under the public domain doctrine falls short.
Second, the Plaintiffs point out that “the information is likely to be commercially obsolete”
because Boeing already began rewriting its software and updating the designs of its aircraft in
response to the crashes. Mot. Summ. J. 14. However, DOJ withheld documents relating to a
broader set of commercial activities, such as Boeing’s “internal operations, compliance programs,
and business strategy[.]” Herrington Decl. ¶ 18. Furthermore, just because a company makes
12
changes to a product over time does not mean that older information is necessarily obsolete. In
other words, beyond speculation about the outdated commercial value of the withheld records, the
Plaintiffs cannot point to sufficient “contrary evidence in the record” or “evidence of agency bad
faith” that is necessary to upset the claims in the Department’s affidavit. Mil. Audit Project v.
Casey, 656 F.2d 724, 738 (D.C. Cir. 1981).
2. Confidential
The Supreme Court established the test for confidentiality under Exemption 4 in Food
Mktg. Inst. v. Argus Leader Media, 588 U.S. 427, 433 (2019). The Court considered two conditions
that might be required. Id. One condition which “has to be” met is that the information “is
customarily kept private, or at least closely held, by the person imparting it.” Id. at 434. The Court
also considered a second condition—whether “the party receiving it provides some assurance that
it will remain secret”—but found “no need to resolve” whether this latter condition was necessary
in that case. Id. at 434–35; see also CREW, 58 F.4th at 1269 (explaining that the D.C. Circuit has
also not determined whether the second condition is mandatory). So “the current law of the D.C.
Circuit . . . is that information is confidential under Exemption 4 if it is of a kind that would
customarily not be released to the public by the person or entity from whom it was obtained.”
Gandhi v. Ctrs. for Medicare & Medicaid Servs., 665 F. Supp. 3d 49, 55 (D.D.C. 2023) (cleaned
up). That said, courts in this District have considered assurances of secrecy in evaluating the
customs and practice of the submitting party. See, e.g., Humane Soc’y Int’l v. U.S. Fish & Wildlife
Serv., No. 16-cv-720, 2021 WL 1197726, at *5 & n.4 (D.D.C. Mar. 29, 2021) (collecting cases for
the proposition that “even after [Argus Leader], courts in this District have continued to recognize
that the circumstances under which a company submits information to the government bears on
whether that information remains confidential”).
13
Here, DOJ fails on the first mandatory condition. DOJ’s declarant provides a total of two
sentences to sustain the agency’s burden on the confidential nature of the withheld records. First,
the declaration states that “[t]he information contained in the withheld records is ‘confidential’
because Boeing would not customarily release this information publicly.” Herrington Decl. ¶ 19.
But this merely recites the relevant legal standard without providing additional details. See
Campbell v. DOJ, 164 F.3d 20, 30 (D.C. Cir. 1998) (explaining that affidavits that are “conclusory
[or] merely reciting statutory standards” cannot meet the agency’s burden on summary judgment).
Moreover, it lacks any explanation about how DOJ’s declarant, the Deputy Chief of the Criminal
Division’s FOIA office, has personal knowledge of Boeing’s confidentiality practices. See
Londrigan v. FBI, 670 F.2d 1164, 1174 (D.C. Cir. 1981) (explaining that the “requirement of
personal knowledge by the affiant is unequivocal, and cannot be circumvented”). Next, DOJ’s
declarant notes that Boeing “stated in letters to the Department that it was requesting confidential
treatment of these records under the FOIA and marked the majority of the records provided as
confidential for purposes of FOIA.” Herrington Decl. ¶ 19. But “these confidential treatment
requests,” while “indicative of [Boeing’s] actual and customary treatment, . . . are not, without
more, sufficient grounds to conclude that the agency met its burden under FOIA.” WP Co. LLC v.
Nat’l Highway Traffic Safety Admin., No. 24-cv-1353, 2026 WL 820742, at *4 (D.D.C. Mar. 25,
2026) (emphasis omitted); see also Ctr. for Auto Safety v. U.S. Dep’t of Treasury, 133 F. Supp. 3d
109, 130 (D.D.C. 2015) (“A company’s request for confidential treatment is not a sufficient basis
for withholding information.”). And DOJ goes no further to explain Boeing’s practices. In
addition, DOJ makes no attempt whatsoever to explain whether and how the three third party
14
entities customarily keep their information private. As a result, DOJ fails to meet its burden to
prove confidentiality under Exemption 4.7
3. Foreseeable Harm
Turning to foreseeable harm, an agency may “withhold information . . . only if [it]
reasonably foresees that disclosure would harm an interest protected by an exemption[.]” 5 U.S.C.
§ 552(a)(8)(A)(i)(I). To do so, it must “articulate both the nature of the harm [from release] and
the link between the specified harm and specific information contained in the material withheld.”
Reps. Comm. for Freedom of the Press v. FBI, 3 F.4th 350, 369 (D.C. Cir. 2021) (internal quotation
marks omitted). Importantly, it “cannot rely on mere speculative or abstract fears . . . [n]or may
the government meet its burden with generalized assertions.” Id. (cleaned up). In this way, “the
foreseeable harm requirement imposes an independent and meaningful burden on agencies.” Id.
Particularly after Argus Leader, “few courts have considered what burden the foreseeable-
harm requirement imposes on agencies that seek to withhold records pursuant to Exemption 4.”
Shteynlyuger v. Ctrs. for Medicare & Medicaid Servs., 698 F. Supp. 3d 82, 123 (D.D.C. 2023).
Still, an “emerging consensus of judges in this district” have “generally agreed that agencies may
meet their burden by demonstrating how disclosure of the requested information would harm the
submitter’s economic or business interests,” WP Co. LLC, 2026 WL 820742, at *11 (cleaned up);
7
The second (possibly inessential) condition identified in Argus Leader considers whether an
agency provided some assurance to the submitting party that its records would remain secret. 588
U.S. at 434. DOJ appears to have met this condition for some (but not all) of the withheld records.
For the six records withheld in full under Exemption 4, which included “commercial information
provided by Boeing to demonstrate compliance with the [deferred prosecution agreement],” DOJ
explains that they were provided “under assurance of confidentiality.” Herrington Decl. ¶ 36.
However, for the remaining records withheld in part under Exemption 4, even though Boeing
asked to keep the records confidential, DOJ never claims that it agreed to do so. In any event,
because DOJ could not clear the first condition of Argus Leader, the second condition has no
impact.
15
see also Ctr. for Investigative Reporting v. U.S. Customs & Border Prot., 436 F. Supp. 3d 90, 113
(D.D.C. 2019) (“To meet this requirement, the defendants must explain how disclosing, in whole
or in part, the specific information withheld under Exemption 4 would harm an interest protected
by this exemption, such as by causing ‘genuine harm to [the submitter’s] economic or business
interests,’ and thereby dissuading others from submitting similar information to the government[.]”
(quoting Argus Leader, 588 U.S. at 441 (Breyer, J., concurring in part and dissenting in part))).
Here, again, DOJ’s declaration is scant. It spends one sentence explaining that “[t]he
release of information concerning Boeing’s internal operations, compliance programs, business
strategy, etc. could clearly cause Boeing competitive harm while a lack of trust that the Criminal
Division will honor requests of confidentiality could harm the Division’s ability to obtain
information from businesses and persons in the future.” Herrington Decl. ¶ 20. This explanation is
too vague. DOJ never attempts to “articulate . . . the nature of the harm,” much less link it to the
“specific information contained in the material withheld.” Reps. Comm., 3 F.4th at 369. In other
words, DOJ does not bother to explain why release of the specific information withheld would
harm the submitter’s economic or business interests. For example, DOJ ignores the Plaintiffs’
arguments that the withheld information may cause little harm to Boeing’s economic or business
interests after subsequent public reporting and disclosures. In fact, as noted above, DOJ did not
file a reply brief at all. As is the case here, “[t]hough an agency is not required to disclose so much
information that it would thwart the purpose of the exemption invoked, summary judgment is
inappropriate where the agency provides only conclusory statements and has not satisfied its
burden of justifying its withholdings.” Pub. Emps. for Env’t Resp. v. Off. of Sci. & Tech. Pol’y,
825 F. Supp. 2d 104, 111 (D.D.C. 2011) (citations omitted). Thus, even if DOJ had established
16
that the withheld information was both commercial and confidential, it would fail to establish
foreseeable harm.
***
DOJ has not carried its burden to show that the withheld information is confidential or that
disclosure would cause foreseeable harm. As a result, the Court will deny its summary judgment
motion with respect to Exemption 4 and grant the Plaintiffs’ motion.
C. Exemptions 6 and 7(C)
DOJ next invoked Exemptions 6 and 7(C) to withhold three categories of information:
“(1) the names and identifying information of Boeing personnel; (2) contact information for
Boeing’s outside counsel, including email addresses, as well as office and mobile phone numbers;
and (3) contact information of DOJ attorneys.” Herrington Decl. ¶ 24. The Court concludes that
DOJ properly withheld the first and third categories but not the second.
“FOIA Exemptions 6 and 7(C) seek to protect the privacy of individuals identified in
certain agency records.” ACLU v. DOJ, 655 F.3d 1, 6 (D.C. Cir. 2011). Exemption 6 permits an
agency to withhold “personnel and medical files and similar files the disclosure of which would
constitute a clearly unwarranted invasion of personal privacy[.]” 5 U.S.C. § 552(b)(6). Exemption
7(C) protects “records or information compiled for law enforcement purposes, but only to the
extent that the production of such law enforcement records or information . . . could reasonably be
expected to constitute an unwarranted invasion of personal privacy[.]” 5 U.S.C. § 552(b)(7)(C).
Because Exemption 7(C) permits the withholding of records “if disclosure would constitute an
‘unwarranted’ invasion of personal privacy, while Exemption 6 requires a ‘clearly unwarranted’
invasion to justify nondisclosure, ‘Exemption 7(C) is more protective of privacy than Exemption
6’ and thus establishes a lower bar for withholding material.” ACLU, 655 F.3d at 6 (quoting U.S.
17
Dep’t of Def. v. FLRA, 510 U.S. 487, 496 n.6 (1994)). For that reason, when an agency claims that
records may be withheld under both exemptions, a court “need only consider whether [the agency]
properly invoked Exemption 7(C).” Id.
To invoke Exemption 7(C), an agency must meet two requirements. First, it must make a
“threshold showing” that the records at issue “were compiled for law enforcement purposes.” Boyd
v. Exec. Off. for U.S. Att’ys, 87 F. Supp. 3d 58, 72 (D.D.C. 2015). When making this showing, “the
focus is on how and under what circumstances the requested files were compiled, and ‘whether
the files sought relate to anything that can fairly be characterized as an enforcement proceeding.’”
Jefferson v. DOJ., Off. of Pro. Resp., 284 F.3d 172, 176–77 (D.C. Cir. 2002) (first citing Weisberg
v. DOJ, 489 F.2d 1195, 1202 (D.C. Cir. 1973); then quoting Aspin v. Dep’t of Def., 491 F.2d 24,
27 (D.C. Cir. 1973)).
After clearing this threshold, the agency faces a balancing test. First, a court will consider
whether disclosure “would compromise a substantial, as opposed to de minimis, privacy interest,”
because “[i]f no significant privacy interest is implicated . . . FOIA demands disclosure.” Nat’l
Ass’n of Retired Fed. Emps. v. Horner, 879 F.2d 873, 874 (D.C. Cir. 1989). In this context, “[a]
substantial privacy interest is anything greater than a de minimis privacy interest.” Multi Ag Media
LLC v. Dep’t of Agric., 515 F.3d 1224, 1229–30 (D.C. Cir. 2008). Second, assuming that it finds
a privacy interest, the court will then “address the question whether the public interest in disclosure
outweighs the individual privacy concerns.” Nat’l Ass’n of Home Builders v. Norton, 309 F.3d 26,
35 (D.C. Cir. 2002). When considering what constitutes the public interest, the court must assess
“the extent to which disclosure of the information sought would ‘she[d] light on an agency’s
performance of its statutory duties’ or otherwise let citizens know ‘what their government is up
18
to.’” U.S. Dep’t of Def. v. FLRA, 510 U.S. at 497 (alteration in original) (quoting DOJ v. Reps.
Comm. for Freedom of Press, 489 U.S. 749, 773 (1989)).
Here, DOJ explains—and the Plaintiffs do not dispute—that the three categories of records
were compiled for “a criminal investigation involving Boeing[.]” Cross-Mot. 11. Therefore, DOJ
satisfie