The entire complaint is available in PDF format.

Complaint for Injunctive and Declaratory Relief

This is an action under the Freedom of Information Act (“FOIA”), 5 U.S.C. § 552, and the Federal Declaratory Judgment Act, 28 U.S.C. §§ 2201 & 2202, for injunctive, declaratory and other appropriate relief. Plaintiffs seeks the expedited processing and release of records concerning the Anti-Counterfeiting Trade Agreement (“ACTA”), a plurilateral trade agreement focused on combating counterfeiting and piracy. Because the requested records involve a matter of substantial public interest, and there is an “urgency to inform the public” about ACTA, plaintiffs are statutorily entitled to the expedited treatment they seek.