Facts

The American Small Business League (ASBL) submitted a request to the United States Small Business Administration (SBA) for information pursuant to the Freedom of Information Act (FOIA). The SBA located and produced the records in its possession pertaining to the request. However, it did so as an .csv file. The ASBL filed suit in USDC Northern against the SBA.

PLAINTIFF'S CONTENTIONS: Plaintiff contended that defendant's response, in providing the requested material as a .csv file, was not in compliance with its FOIA request, and it was also entitled to a more workable .bak file.

DEFENDANT'S CONTENTIONS: Defendant contended that it was only obligated to produce records that were in its possession responsive to the request, and it did so; plaintiff's original request made no mention of any desired file format other than asking that the produced records be contained in a single database to the extent possible. Moreover, as plaintiff's original FOIA request failed to mention what criteria to use in determining or verifying whether a business was "small," plaintiff was not entitled to those records and, it has no such records because it does not independently assess the size of the businesses on its yearly reports.

Result

The court granted defendant's motion for summary judgment.