OPINION AND ORDER Plaintiff Osen LLC (Osen) brought this action pursuant to the Freedom of Information Act (FOIA), 5 U.S.C. §552, against United States Central Command (CENTCOM), seeking unredacted copies of documents related to attacks on American military personnel in Iraq between 2004 and 2011. Now before the Court are the parties’ cross-motions for summary judgment, which turn on the narrow issue of whether CENTCOM properly relied on FOIA Exemption 6, which applies to information that “would constitute a clearly unwarranted invasion of personal privacy” if disclosed, 5 U.S.C. §552(b)(6), when it redacted the names and photographs of foreign nationals suspected to be malign actors. For the reasons set forth below, CENTCOM’s motion (Dkt. No. 21) will be granted in part, Osen’s cross-motion (Dkt. No. 26) will be denied, and the Court will leave the case open for the parties to resolve certain limited outstanding issues discussed below. I.BACKGROUND A. Factual Background Osen is a law firm, with offices in New Jersey and New York, “that primarily represents victims of international terrorism.” Compl. (Dkt. No. 9) 12. Osen “represents hundreds of U.S. service members and family members of U.S. service members” who were “killed or injured in terrorist attacks while serving in Iraq,” alleging “that these attacks were committed by Iranian- backed terrorists, and that Iran and its corporate enablers are responsible” for its clients’ injuries. Id. 2. Osen has filed “several lawsuits against Iran and several Iranian and Western financial institutions that it alleges helped Iran fund, train, and otherwise support the terrorists” who allegedly injured Osen’s clients. Id. Osen has also filed several lawsuits in this District against various agencies of the U.S. government, including CENTCOM,1 seeking the disclosure of government records to assist it in showing “that Iran was responsible for the attacks in which [its clients] were injured.” Compl. 3. See also Osen LLC v. United States Cent. Command, No. 1:17-cv-04457-KPF (S.D.N.Y.); Osen LLC v. Office of Foreign Assets Control of the U.S. Dep’t of Treasury, No. 1:18-cv-03511-JPO (S.D.N.Y.); Osen LLC v. U.S. Dep’t of Commerce, Bureau of Industry and Security, No. 1:18-cv-06066-PGG (S.D.N.Y.); Osen LLC v. U.S. Dep’t of State, No. 1:18-cv-06070-JSR (S.D.N.Y.); Osen LLC v. Office of Foreign Assets Control of the U.S. Dep’t of Treasury, No. 1:19-cv-00405-AJN (S.D.N.Y.); and Osen LLC v. United States Cent. Command, No. 1:19-cv-06867-KPF (S.D.N.Y.). On December 27, 2017 and April 6, 2018, Osen submitted the two sets of FOIA requests at issue in this case. Compl.
7, 25, 31, & Exs. A, C. Those requests sought disclosure of 32 weekly reports from General David Petraeus (the then-commander of U.S. and allied forces in Iraq) to Secretary of Defense Robert Gates in 2007 and 2008, 37 Significant Activities (SIGACT) Reports from 2004 through 2009, and 13 other military or intelligence reports. Id. Exs. A, C. B. Procedural Background Osen filed its complaint on July 5, 2018, seeking a declaration that “CENTCOM is obligated to provide it with copies of the records sought,” and an injunction compelling CENTCOM to provide the same records. Compl.