Judicial Watch v. FDA (D.D.C.) -- in case involving government’s acquisition of human fetal tissue for research, concluding that: (1) government improperly relied on Exemption 4 to withhold names and addresses of laboratories because it failed to adequately explain how such information qualified as “commercial” information; and (2) government improperly withheld unit prices and line-item amounts pursuant to Exemption 4, because plaintiff demonstrated that such information was in the public domain. Lastly, the court noted that Exemption 4 could not be used to protect illegal business practices and that there was reason to believe that the government’s transactions with a laboratory were unlawful, but the court found it unnecessary to reach a decision on that issue,
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