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FOIADetermination Letter (non-binding)Closed no further actionFees & Burdensome Requests

PAC cannot review University of Illinois FOIA denial for commercial purpose

The requester sought training materials developed by the University for the Illinois Health Insurance Marketplace to assist in a competitive bidding process.

Date issued
July 30, 2015
Request number(s)
36229
Public body
University of Illinois
Statute(s)
5 ILCS 140/9.5
Exemption(s) discussed
7(1)(j)(iv) — Faculty course/research materials7(1)(q) — Licensing/employment exam questions and scoring keys
Outcome
Closed due to commercial purpose

Plain-language summary

A requester asked the University of Illinois for training materials to help his company win a government contract. The Attorney General's office decided it could not help him challenge the University's refusal to provide the records because the law prohibits the PAC from reviewing requests made for commercial purposes. The requester must now file a lawsuit in court if he wishes to pursue the records further.

Legal question

Does the Public Access Counselor have the authority to review a FOIA denial when the underlying request was submitted for a commercial purpose?

Holding

The PAC cannot review the denial of a FOIA request when the requester is seeking records for a commercial purpose.

Summary

The requester sought training materials from the University of Illinois, but the PAC determined it lacked jurisdiction to review the denial because the request was made for a commercial purpose.

commercial purposePAC jurisdictionFOIA denialUniversity of Illinois

Extracted text (667 words)

Text extracted from the PDF. Where source line breaks survive, they are used to reconstruct paragraphs; where they do not, the text is split into display-only reading blocks at sentence boundaries. Repeating office address blocks and safely identified footnotes are removed from the reading flow where possible. Reconstruction is automatic and imperfect — the PDF is the authoritative version, and it's linked on this page.

OFFICE OF THE ATTORNEY GENERAL

STATE OF ILLINOIS

Lisa Madigan

ATTORNEY GENERAL

July 30, 2015

Via electronic mail

Mr. Tom Ripperda

Educational Concepts Unlimited, Inc.

3301 West Main Street

[street address redacted for site publication -- see original PDF]

RE: FOIA Request for Review ~ 2015 PAC 36229

Dear Mr. Ripperda:

The Public Access Bureau received your Request for Review, pursuant to section 9.5(a) of the Freedom of Information Act (FOIA) (5 ILCS 140/9.5(c) (West 2014)) concerning a FOIA request that you submitted to the University of Illinois (University). For the reasons that follow, the Request for Review process is not available in this instance because you requested records for a commercial purpose.

On May 4, 2015, you submitted a FOIA request to the University, which was subsequently narrowed on June 3, 2015, seeking, among other things, copies of a PowerPoint presentation and handouts that the University developed pursuant to a contract with the Illinois Health Insurance Marketplace to provide training to assistors and navigators under the Patient Protection and Affordable Care Act (42 U.S.C. § 18001 ef seq. (2010)); see also 45 C.F.R. § 155.205(d) (2015)). On July 2, 2015, the University denied your request for the PowerPoint presentation and handouts asserting that those records are exempt from disclosure pursuant to sections 7(1)(j)(iv) and 7(1)(q) of FOIA (5 ILCS 140/7(1)()(iv), 711 (q) (West 2014)). On July 9, 2015, this office received your Request for Review contesting the University's denial.

Section 9.5(a) of FOIA (5 ILCS 140/9.5(a) (West 2014)) allows a person whose FOIA request is denied to seek review of that denial with the Public Access Counselor.

record or records, or information derived from public records, in any form for sale, resale, or solicitation or advertisement for sales or services." (Emphasis added.) Under section 9.5(b) of FOIA, the Public Access Counselor's review process is not available to a person whose request was made for a commercial purpose.

Your FOIA request was not identified on its face as being for a commercial purpose. However, your Request for Review clarifies that you are seeking the information in question for the purpose of placing a bid with the Illinois Department of Health so that your company can be the lowest bidder and enter into a contract to provide the training to assistors and navigators. In other words, you seek to use the information requested from the University to solicit the sale of your training services, which constitutes a "commercial purpose" under FOIA. Because you are seeking the PowerPoint presentations and handouts from the University for a commercial purpose, section 9.5(b) of FOIA precludes the Public Access Counselor from reviewing this matter. Please note that you have the option of filing suit for injunctive or declaratory relief pursuant to section 11 of FOIA (5 ILCS 140/11 (West 2014)).

If you have any questions or would like to discuss this matter, please contact me at (312) 814-5201. This letter closes this matter.

Very truly yours,

EDIE STEINBERG

Assistant Attorney General

Public Access Bureau

36229 f no fi war univ Ce: Via electronic mail

Mr. Thomas P. Hardy

Executive Director and Chief Records Officer

University of Illinois

414 Administrative Office Building

1737 West Polk Street, MC-971

Chicago, Illinois 60612

[email protected]