began keeping copies of all American naturalization records. The naturalization certificate files would come to be known as C-Files. Additionally, those who had acquired their citizenship on questionable legal grounds, are now subject to additional scrutiny, as a direct result of this law. Section 15 clearly outlines the powers granted to U.S. attorneys towards prosecuting these cases, with language giving a considerable amount of the burden of proof to defendants. This provision was quite encompassing, thus promoting a number of prosecutions on the basis of fraudulent naturalization procedures. The case of Luria v. United States challenges this provision, but it is deemed constitutional. Particularly significant about this legislation is that it clearly asserts greater federal jurisdiction over the naturalization process in America. If the existence of the act, on its own, does not elicit that impression, then Section 11's assertion that the United States can appear "before any court" as it relates to naturalization proceedings makes it more explicit. This provision does not technically strip the states of any jurisdiction, but it specifically asserts that the federal government holds the ultimate powers relating to naturalization, under the law. Another case that was directly affected by this legislation was Takao Ozawa v. United States. Part of the justification for the courts decision to not allow Ozawa's attainment of citizenship was that, traditionally, only white persons were allowed citizenship. The Naturalization Act of 1906 does not specifically address the addition of any groups that may wish to attain American citizenship. The opinion specifically states: "In all of the naturalization acts from 1790 to 1906 the privilege of naturalization was confined to white persons [260 U.S. 178, 193] (with the addition in 1870 of those of African nativity and descent), although the exact wording of the various statutes was not always the same. If Congress in 1906 desired to alter a rule so well and so long established it may be assumed that its purpose would have been definitely disclosed and its legislation to that end put in unmistakable terms." The decision goes on to deny that the common population could construe Ozawa, a man of Japanese descent, as white (thus, making him ineligible under section 2169 of the Revised Statutes of the United States). Thus he could not be naturalized, under the current laws, in 1922. Factors leading to passage of the law Since 1802, states had been tasked with determining procedures