The following excerpt is from Roe v. Sherry, 91 F.3d 1270 (9th Cir. 1996):
the type of [information] requested, ... the potential for harm in any subsequent nonconsensual disclosure, ... the adequacy of safeguards to prevent unauthorized disclosure, [and] the degree of need for access....
Id. (quoting United States v. Westinghouse Elec. Corp., 638 F.2d 570, 578 (3rd Cir.1980)).
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