Opinion for the Court filed by Circuit Judge TATEL.
TATEL, Circuit Judge:
When the State Department responds to Freedom of Information Act requests, it generally declines to search for documents produced after the date of the requester's letter. Challenging this "date-of-request cut-off" policy, appellant claims that the Department promulgated it without notice and opportunity to comment as required by the Administrative Procedure Act, and that, in any event...
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