Challenge Coin design (Office of the Director of National Intelligence)

Emma North-Best filed this request with the Office of the Director of National Intelligence of the United States of America.
Tracking #


Multi Request Challenge Coin design


From: Emma North-Best

To Whom It May Concern:

Pursuant to the Freedom of Information Act, I hereby request the following records:

Records relating to the design of challenge coins, including guidelines, policies, proposed, accepted and rejected designs, as well as discussion, deliberation, and debate about possible designs and design policies.

I am a member of the news media and request classification as such. I am freelance writer who has previously written about the government and its activities for MuckRock, Motherboard, Unicorn Riot, AND Magazine and Glomar Disclosure. My articles have been widely read, with some reaching over 100,000 readers. My work has been further discussed in outlets including the New York Times, the Washington Post, and BBC. As such, as I have a reasonable expectation of publication and my editorial and writing skills are well established. In addition, I discuss and comment on the files online and make them available through the non-profit Internet Archive, disseminating them to a large audience. While my research is not limited to this, a great deal of it, including this, focuses on the activities and attitudes of the government itself. As such, it is not necessary for me to demonstrate the relevance of this particular subject in advance. Additionally, case law states that “proof of the ability to disseminate the released information to a broad cross-section of the public is not required.” Judicial Watch, Inc. v. Dep’t of Justice, 365 F.3d 1108, 1126 (D.C. Cir. 2004); see Carney v. U.S. Dep’t of Justice, 19 F.3d 807, 814-15 (2d Cir. 1994). Further, courts have held that "qualified because it also had “firm” plans to “publish a number of . . . ‘document sets’” concerning United States foreign and national security policy." Under this criteria, as well, I qualify as a member of the news media. Additionally, courts have held that the news media status "focuses on the nature of the requester, not its request. The provision requires that the request be “made by” a representative of the news media. Id. § 552(a)(4)(A)(ii)(II). A newspaper reporter, for example, is a representative of the news media regardless of how much interest there is in the story for which he or she is requesting information." As such, the details of the request itself are moot for the purposes of determining the appropriate fee category. My primary purpose is to inform about government activities by reporting on it and making the raw data available and I therefore request that fees be waived. Per DOJ FOIA guidance, "a requester should be granted a fee waiver if the requested information (1) sheds light on the activities and operations of the government; (2) is likely to contribute significantly to public understanding of those operations and activities; and (3) is not primarily in the commercial interest of the requester." As this FOIA meets all of those requirements (see above regarding the subject and how I will apply the information), a fee waiver is warranted.

The requested documents will be made available to the general public, and this request is not being made for commercial purposes.

In the event that there are fees, I would be grateful if you would inform me of the total charges in advance of fulfilling my request. I would prefer the request filled electronically, by e-mail attachment if available or CD-ROM if not.

Thank you in advance for your anticipated cooperation in this matter. I look forward to receiving your response to this request within 20 business days, as the statute requires.


Emma Best

From: Office of the Director of National Intelligence

An acknowledgement letter, stating the request is being processed.

From: Office of the Director of National Intelligence

Good afternoon,

Thanks for your request.

Your request is currently in our queue to be worked. Please note there are 505 cases ahead of yours, until the status of your request changes, we will not provide any further updates.


From: Office of the Director of National Intelligence

Good Morning Ms. Best,

Thank you for your FOIA request of May 9, 2018 where you requested "records relating to the design of challenge coins; including guidelines, policies, proposed, accepted and rejected designs; as well as discussion, deliberation, and debate about possible designs and design policies.” The assigned case number is DF-2018-00173.

The searches were initiated, however, during this process we realized that we need you to be more specific with the definition of "challenge coin". In order to speed up the search process, please also indicate if there is a specific component of the ODNI that you are interested in.

Thank you.


From: Emma North-Best

A challenge coin is a small coin or medallion, bearing an organization’s insignia or emblem and carried by the organization’s members. Traditionally, they are given to prove membership when challenged and to enhance morale. In addition, they are also collected by service members. In practice, challenge coins are normally presented by unit commanders in recognition of special achievement by a member of the unit. I am not limiting the request to a specific component or office.

From: Muckrock Staff

To Whom It May Concern:
I wanted to follow up on the following request, copied below. Please let me know when I can expect to receive a response.
Thanks for your help, and let me know if further clarification is needed.

From: Office of the Director of National Intelligence

Good afternoon, Ms. Best-

DNI-FOIA is reaching out to you again to see if you would be willing to limit your request (for “records relating to the design of challenge coins…”) to one or more specific ODNI components?

We have determined there is no over-arching ODNI policy guiding the design of challenge coins. As such, each office may develop their own policy and any responsive records would be maintained by individual offices. A thorough search would require looking in dozens of components, with an unknown number of sub-components, for potentially responsive records, and take an exorbitant amount of time.

We propose limiting the search to only the Information Management Office. Pre-publication and classification reviews are housed here. While coins are not required to be reviewed by that office, components do occasion submit designs for that purpose. In our opinion, this would be the only ODNI component that is likely to have records on the coin designs that are not specific to their office.

Additionally, there are a few internal ODNI Instructions which mention coins. As those instructions are not design-specific, they are not responsive to your original request. However, we are will to consider those records responsive, particularly in lieu of search individual ODNI components. Please let us know.

Please respond within 30 days with guidance on how you wish to proceed or we will administratively close your case.

Thank you,

From: Emma North-Best

Your suggestions are all acceptable. Thank you for reaching out.

From: Office of the Director of National Intelligence

A copy of documents responsive to the request.

From: Office of the Director of National Intelligence

A copy of documents responsive to the request.