n. ~ A lawsuit (Armstrong v. Executive Office of the President, 1 F.3d 1274 [DC Cir 1993]) filed by Scott Armstrong, American Historical Association, the American Library Association, the Center for National Security, and others, relating to access to and the disposition of email records.
The case takes its name from the IBM PROFS (Professional Office System) email system used in the White House. In a later opinion, the US Court of Appeals also held that National Security Council staff solely advise and assist the president and thus create presidential records not immediately subject to the Freedom of Information Act (see Armstrong v. Executive Office of the President, 90 F.3d 553 (D.C. Cir. 1996), cert. denied, 520 U.S. 1239 (1997)).