RANDALL, Circuit Judge:
This appeal raises the narrow question whether the Privacy Act, 5 U.S.C. § 552a, is a "statute" within the meaning of one provision of the Freedom of Information Act (FOIA), 5 U.S.C. § 552(b)(3). That subsection of the FOIA provides that the FOIA does not apply to matters that are "specifically exempted from disclosure by statute," as long as the exempting statute meets certain basic requirements.
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