American Transparency v. U.S. Department of Health and Human Services

CourtDistrict Court, District of Columbia
DecidedSeptember 30, 2025
DocketCivil Action No. 2021-2821
StatusPublished

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American Transparency v. U.S. Department of Health and Human Services, (D.D.C. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

_________________________________________ ) AMERICAN TRANSPARENCY, ) d/b/a OpenTheBooks.com, ) ) Plaintiff, ) ) v. ) Civil No. 21-cv-02821 (APM) ) U.S. DEPARTMENT OF HEALTH AND ) HUMAN SERVICES, ) ) Defendant. ) _________________________________________ )

MEMORANDUM OPINION AND ORDER

I.

Plaintiff in this case is American Transparency, d/b/a OpenTheBooks.com, whose

“mission is to post online all publicly available government spending.” Compl., ECF No. 1, ¶ 3.

Plaintiff submitted a Freedom of Information Act (FOIA) request to the National Institutes of

Health (NIH), a component of Defendant U.S. Department of Health and Human Services, seeking

information about the royalties paid to its employees. After Plaintiff filed the instant action to

compel production, Defendant released records of most of the information Plaintiff sought. But

Defendant withheld the amounts of individual royalty distributions paid to NIH-employed

inventors pursuant to Exemptions 3, 4, and 6.

Before the court are Defendant’s Motion for Summary Judgment, ECF No. 24 [hereinafter

Def.’s Mot.], and Plaintiff’s Cross-Motion for Summary Judgment, ECF No. 28 [hereinafter Pl.’s

Mot.]. The court denies both motions. The court agrees with Plaintiff that Defendant may not

withhold the requested information pursuant to Exemption 6. However, there is a genuine dispute of material fact as to whether Defendant properly withheld the requested information pursuant to

Exemptions 3 and 4.

II.

On September 15, 2021, Plaintiff submitted a FOIA request to NIH, seeking:

A complete list/database of all personal royalties paid (including, but not limited to, FY2020) to current and former National Institutes of Health employees for work done while they were federally employed. The list/database should include, but not be limited to, the royalty recipient’s name, the amount of the royalty, the reason for the royalty, the date the royalty was paid, and the name of the entity paying the royalty.

Def.’s Mot., Ex. 2, ECF No. 24-4. Approximately one month later, having received only an

acknowledgment letter, Plaintiff filed this action to compel production. Compl. By September

2022, Defendant had provided Plaintiff with nine productions and a final response to its request.

Def.’s Mot., Def.’s Stmt. of Material Facts Not in Genuine Dispute, ECF No. 24-2 [hereinafter

Def.’s Stmt.], ¶ 5. After Plaintiff inquired about some of the information Defendant withheld,

Defendant re-released 2,945 pages to Plaintiff with additional information included. Id. ¶¶ 7–8.

This largely satisfied Plaintiff’s request. Pl.’s Mot., Pl.’s Stmt. of Material Facts, ECF No. 28-2

[hereinafter Pl.’s Stmt.], ¶ 10. But Defendant continued to withhold the information at issue here—

the royalty distributions paid to inventors—under Exemptions 3, 4, and 6. Id. ¶ 9.

These so-called “inventor awards” are the amounts NIH pays its scientists after a private

company licenses NIH-owned technology. Def.’s Stmt. ¶ 9; Def.’s Reply in Supp. of Summ. J. &

Resp. to Pl.’s Mot., ECF No. 33 [hereinafter Def.’s Reply], Def.’s Suppl. Stmt. of Material Facts,

ECF No. 33-1 [hereinafter Def.’s Suppl. Stmt.], at 11, ¶ 14. When a private company seeks to

license NIH-owned technology, it must propose and then negotiate how much it will pay NIH in

royalties. Def.’s Suppl. Stmt. at 11, ¶ 11. NIH then distributes a portion of those royalties to its

2 scientist(s) who invented the technology. Id. at 10, ¶ 6. The governing statute mandates that NIH

pay the inventor(s) “the first $2,000, and thereafter at least 15 percent, of the royalties” received

from the licensee each year. 15 U.S.C. § 3710c(a)(1)(A)(i). NIH represents that it pays its

inventors the first $2,000, 15% of the royalties above $2,000 and up to $50,000, and 25% of the

royalties above $50,000. Def.’s Suppl. Stmt. at 13, ¶ 27. An inventor may not receive more than

$150,000 in aggregate royalty distributions annually. 15 U.S.C. § 3710c(a)(3).

From 2006 to 2022, NIH scientists collectively received anywhere from $7.6 million to

$15 million in royalty distributions each year. Pl.’s Stmt. ¶ 20. These royalty payments have

received attention from both the press and political officials. Id. ¶¶ 21, 23.

The court first ordered the parties to meet and confer about Plaintiff’s request in November

2021. Order, ECF No. 9. After two years of periodically updating the court on Defendant’s

progress in responding to it, the parties filed these cross-motions for summary judgment.

III.

The court will 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). A “material” fact is one “that might affect the outcome of the suit.” Anderson v.

Liberty Lobby, Inc., 477 U.S. 242, 248 (1986).

In FOIA cases, the burden is on the agency to show that an exemption applies. Alyeska

Pipeline Serv. v. EPA, 856 F.2d 309, 311 (D.C. Cir. 1988). The agency must show that (1) the

requested materials fall within the scope of the exemption, and (2) “it is reasonably foreseeable

that release of those materials would cause harm to an interest protected by” the exemption.

Reps. Comm. for Freedom of the Press v. FBI, 3 F.4th 350, 361 (D.C. Cir. 2021) (citing 5 U.S.C.

§ 552(a)(8)(A)(i)(I)). Where, as here, the agency has attempted to support its invocation of the

3 exemption by affidavit, the court will grant the agency summary judgment “when the affidavits

describe the justifications for nondisclosure with reasonably specific detail, demonstrate that the

information withheld logically falls within the claimed exemption, and are not controverted by

either contrary evidence in the record nor by evidence of agency bad faith.” Larson v. U.S. Dep’t

of State, 565 F.3d 857, 862 (D.C. Cir. 2009) (internal quotation marks omitted).1 Summary

judgment is inappropriate, however, when the plaintiff provides “specific facts demonstrating that

there is a genuine issue with respect to whether the agency has improperly withheld extant agency

records” under the claimed exemption. Span v. U.S. Dep’t of Just., 696 F. Supp. 2d 113, 119

(D.D.C. 2010) (internal quotation marks omitted). When that is the case, the court must hold an

evidentiary hearing or bench trial to resolve the outstanding dispute. Scudder v. CIA, 25 F. Supp.

3d 19, 29 (D.D.C. 2014).

The court begins with Exemption 6. The court then discusses Exemptions 3 and 4, which

rise and fall together.

A.

Exemption 6 allows 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).

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