II. "Clearly Unwarranted Invasion of Personal Privacy"

In addition to challenging whether the type of record falls under those categories of records contemplated by Exemption 6, you should also argue that there is little or no privacy interest in the information based on the nature of the information itself or certain attributes of the person whose privacy may be at issue. Exemption 6 protects “‘the individual’s control of information concerning his or her person.’”¹³

¹³ U.S. Dep’t of Def. v. Fed. Labor Relations Auth., 510 U.S. 487, 500 (1994) (quotingU.S. Dep’t of Justice v. Reporters Comm. for Freedom of the Press, 489 U.S. 749, 763 (1989)).