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Obtaining protection for business secrets in an agency proceeding is at best an imperfect art. The lack of any uniform rule and the confusion and delay which result from an ad hoc approach are highlighted by FCC v. Schreiber. The authors examine the current state of the law in light of the Schreiber decision and point up the present inequities. Their conclusion is that the situation can only be remedied by enactment of regulatory in camera procedures for all federal agencies. A model for such a regulation is appended to the article.



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