large would not meet this criterion). It also allowed documents requested under the FOIA or Privacy Act to be classified or reclassified provided they met specified requirements (e.g., certain matters related to national security). According to Bamford, he could not be prosecuted under the new rules because of the principle of ex post facto. Reclassified source documents and American Library Association lawsuit Reclassified and re-sequestered source documents that Bamford had used when writing The Puzzle Palace were the subject of subsequent litigation. The NSA's historical account states that documents removed from the Marshall Library were "sequestered portions of the Friedman collection," i.e., the collection that included the copies of the NSA Newsletter that spurred one of Bamford's FOIA requests. The materials removed from circulation included three government publications and 31 pieces of Friedman's private correspondence. The American Library Association (ALA) challenged the document removal in court, and in 1987 the U.S. Court of Appeals for the District of Columbia dismissed the case. Ruth Bader Ginsburg, who was at that time a Court of Appeals judge, ruled that the ALA lacked standing in the case. A lower court ruling had already affirmed that the NSA had authority to remove the reclassified documents, but criticized the NSA's "cavalier attitude" toward the classification determination of those documents. Reviews and reception The New York Times reviewed the book favorably, writing that "Until now no one has published a comprehensive and detailed report on the agency. The quality and depth of Mr. Bamford's research are remarkable." The review concluded, "By revealing the scope and opening up the operations of the N.S.A. without giving away its most sensitive secrets, Mr. Bamford has performed an important public service in this impressive book." In a review of Shane Harris' book The Watchers: The Rise of America's Surveillance State, New York Times reporter Eric Lichtblau described The Puzzle Palace as "the benchmark study of the N.S.A. [that] first pulled back the curtain to provide a glint of unwanted sunlight on the place". Michael Duffy, reviewing Bamford's 2004 book Pretext for War, wrote in Time magazine that The Puzzle Palace "is still considered the classic account of the mysterious National Security Agency." The Puzzle Palace has been generally well received by experts, and has been used as a textbook at the Defense Intelligence Agency's National Intelligence University. The NSA itself says the book "brought a new focus to the efforts