An analysis of the FOIA’s controversial “catch-all exemption,” its recognized scope to date, and its future application under the OPEN FOIA Act of 2009 (the “2009 FOIA Amendment”). Jason I. Allen, Senior Research Assistant, Collaboration on Government Secrecy, Washington College of Law; Kevin M. Goldberg, Special Counsel, Fletcher, Heald & Hildreth, P.L.C.; Matthew L. Johnson, Chief Counsel to Senator John Cornyn for Senate Judiciary Committee; and Adina H. Rosenbaum, Director, Freedom of Information Clearinghouse, Public Citizen Litigation Group