FOIA’s legal right of action to sue (or threaten to sue) for information disclosure when records are withheld remains essential for ensuring access to data of public import until other mechanisms are put in place to mandate open data disclosures. … The significance of the decision is that the IRS now makes all electronically filed nonprofit tax returns digitally downloadable as open data.

David E Pozen; Michael Schudson, Troubling Transparency- The…, loc. 1041