DC Circuit: National Security Counselors v. CIA

Fees

A bona fide corporation with an identity distinct from that of the natural person who represents it in court is eligible for fee-shifting provisions of FOIA.  In house counsel presumptively distinct from corporation, despite close involvement and personal commitment.

https://www.cadc.uscourts.gov/internet/opinions.nsf/EBD08628AB46B5D185257F3B0054CBEF/$file/14-5171-1593790.pdf