Jensen v. SEC, No. 23-01811, 2025 WL 671102 (D.D.C. Mar. 3, 2025) (Reyes, J.)

Jensen v. SEC, No. 23-01811, 2025 WL 671102 (D.D.C. Mar. 3, 2025) (Reyes, J.)

Re: Request for certain contract agreements

Disposition:  Granting defendant’s motion for summary judgment; denying plaintiff’s cross-motion for summary judgment

• Litigation Considerations, Adequacy of Search:  “[T]he Court is satisfied that the SEC’s searches were adequate and reasonable under the circumstances.”  “The Court finds that [defendant’s] Declaration sets forth in reasonable detail, and in good faith, the type of information the agency (and its relevant components) retains, how it is organized, and how searches using the database are conducted.”  “[Defendant] specifically describes why [the particular location searched] was searched, why the security names and ticker symbols were used as terms, avers that the searches were reasonable, and clearly explains why no responsive records were found.”  “Plaintiff focuses heavily on the SEC’s alleged failure to properly tailor its searches to uncover [certain information].”  “But [the court finds that] Plaintiff did not make clear in either FOIA Request that he sought [certain] information. . . .” “The SEC could not have plausibly discerned Plaintiff’s objective.”  Separately, the court finds that plaintiff’s “speculation that documents were or should have been found does not undermine the SEC’s otherwise reasonable searches.”