Our research suggests that there are a number of objectively discernible similarities between the U.S. FOIA and RTI laws from countries around the world, adopted at different times and demonstrating different levels of strength as measured against international standards. We have not assessed the question of causality regarding these similarities, but it seems reasonable to posit that at least some of the similarities must have been due to borrowing from the FOIA model. At the same time, our research indicates that in relation to many of the more important features of RTI laws, as identified through the RTI Rating, cases of divergence from the U.S. FOIA are far more prominent than those of borrowing from it. These results disprove any notion that FOIA has been transplanted abroad in its totality, and they unsettle the often unquestioned assumption that it had at least a major impact on the design of foreign RTI laws. This is hardly surprising, but our results tend to confirm the view that significant innovation and development in RTI practice have been occurring outside the United States.

David E Pozen; Michael Schudson, Troubling Transparency- The…, loc. 1326