On November 29, 2012, the Office of Hearings and Appeals (OHA) issued a decision denying an appeal (Appeal) from a Freedom of Information Act (FOIA) determination issued by the Golden Field Office (GFO). The Appellant appealed the GFO’s decision to withhold portions of the released documents pursuant to Exemption 4. The Appellant claimed that Exemption 4 could not apply as the company whose records the Appellant was seeking, Abound Solar, commenced bankruptcy proceedings, and therefore, did not have any “commercial interests” to protect from the public. However, OHA determined that despite the pending bankruptcy proceedings, Abound Solar may nonetheless suffer competitive harm from the released information, and therefore it may be entitled to protection under Exemption 4. Thus, OHA denied the Appeal.