Litigation considerations, Adequacy of Search: The court holds that defendant remedied all of the deficiencies highlighted by the Court of Appeals. The court relates that, "[o]n remand, the DEA provided an additional declaration addressing the gaps identified by the Court of Appeals[,]" "i.e., search terms and the type of search performed." The court relates that defendant's declaration also contains "why searching [certain] indices was reasonably likely to disclose all relevant information."
Procedural Requirements, "Agency Records": The court holds that "[t]he map images [plaintiff] seeks would involve the addition to the GPS 'ping' data of explanatory material in the form of geographical locations, streets, as well as other new information such as the Google maps logo and Google formatting styles and conventions." "FOIA does not obligate the DEA to create new explanations to render the requested records more comprehensible." "The multiple steps between the spreadsheets and the requested images – opening some sort of mapping software, inputting the data from 351 pages of spreadsheets, and generating a new map image for each 'ping' – strongly suggests that the output would not be a straightforward reproduction of the spreadsheets, but a new record with significant added meaning."