Courthouse News reports that the State Department has been allowed to withhold material concerning a discussion pertaining to a letter written by Plaintiff Arthur Houghton about the Department's Cultural Property Advisory Committee. United States District Court for the District of Columbia Judge Amy Berman found the material properly withheld pursuant to Exemption 3 via 19 U.S.C. Section 2605(h). However, Judge Berman found the State Department did not adequately explain its search for other records and order further searches and briefing on that issue. The opinion can be found here.