Public interest balancing in the context of those exemptions. [fact]
Although two of FOIA’s privacy exemptions already incorporate a species of public interest balancing, those exemptions concern individual privacy interests. … Public interest balancing in the context of those exemptions thus serves a somewhat distinct function and has been limited in its application by court decisions.
David E Pozen; Michael Schudson, Troubling Transparency- The…, loc. 1127