On March 18, 2021, the U.S. Court of Appeals for the District of Columbia Circuit heard oral argument in The Protect Democracy Project v. U.S. National Security Agency, a case in which appellant seeks access to communications between NSA and the Executive Office of the President regarding Russian interference with the 2016 presidential election. The lower court held that NSA properly withheld a disputed memorandum pursuant to Exemption 5’s presidential communications privilege.