1. Some lower courts that did recognize a privilege for information possessed by the Census Bureau during the interim period between St. Regis and Baldrige did so not by relying on either St. Regis's holding or the plain text of section 9(a), but rather by using their common law authority to conduct the careful balancing required before courts may recognize new common law privileges;See Carey v. Klutznick, 653 F.2d,1975
2. No. 1118. United Nations Industrial Development Organization and League of Arab States