Inst. for Energy Research v. FERC (D.D.C.) -- concluding that: (1) agency conducted adequate search for records, noting that agency reasonably defined a “record” as a single text message (as opposed to “threads”) given plaintiff’s request for specific text messages containing certain terms; (2) FERC properly withheld records pursuant to Exemption 5’s deliberative process privilege, but failed to show foreseeable harm for all but one withholding; and (3) FERC properly relied on Exemption 6 to withhold name of a prospective agency employee and all cellphone numbers (and that the foreseeable harm test was met), but it improperly withheld the names of two employees.

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