The NSA is a very difficult nut to crack as far as FOIA is concerned. Not only does the NSA invoke national defense here, as well as the Espionage Act, they also invoke the NSA Act of 1959, which—though the NSA Act of 1959 was passed years before the Freedom of Information Act was passed, the NSA has succeeded in convincing the courts that the NSA Act of 1959 exempts the NSA entirely from the obligations of FOIA. And so, the only times the NSA complies with the Freedom of Information Act is when it wants to, which is when the release of records will make the NSA look good, and it should therefore be unsurprising that the recent AP report found that the NSA failed to comply with the—or, denied FOIA requests 98 percent of the time last year.