Bloomberg L.P. and Dow Jones & Company, Inc. v. United States Postal Service
The Second Circuit affirmed the district court's grant of summary judgment to the USPS, holding that aggregated change-of-address data qualifies as information of a commercial nature under the Postal Reorganization Act. The court ruled that FOIA Exemption 3 bars disclosure of this data because the underlying statute establishes specific criteria for withholding commercial information derived from the agency's core business operations.