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MEMORANDUM AND ORDER The American Society for the Prevention of Cruelty to Animals (“ASPCA”) brought this case under the Freedom of Information Act, 5 U.S.C. §552 (“FOIA”), against the United States Department of Agriculture (“USDA”) and its constituent agency the Animal and Plant Health Inspection Service (“APHIS” and together with USDA, the “Agencies”). This case presents three broad issues. First, the APSCA challenges the Agencies’ redactions of certain information under FOIA Exemption 4, which protects confidential business information. Next, the ASPCA contends that the Agencies improperly withheld information under FOIA Exemption 5, which shields privileged information from disclosure. Finally, the ASPCA charges that the Agencies have adopted a policy and practice of violating the FOIA that requires the Court’s intervention. The parties cross-move for summary judgment on the Agencies’ application of Exemptions 4 and 5. (ECF Nos. 42, 49.) The Agencies move for judgment on the pleadings on the ASPCA’s policy and practice claim (ECF No. 42) and the parties also cross-move for summary judgment on that claim (ECF Nos. 42, 49). For the reasons discussed below, the Court grants in part and denies in part the parties’ cross-motions for summary judgment on the Agencies’ assertions of the FOIA exemptions and grants the Agencies’ motion for judgment on the pleadings on the ASPCA’s policy and practice claim. BACKGROUND A. The Freedom of Information Act The FOIA requires that federal agencies make their records “promptly available to any person” upon request. 5 U.S.C. §552(a)(3)(A). This mandatory disclosure regime is limited by nine statutory exemptions. Id. §552(b). Moreover, even when information falls under one or more of those exemptions, agencies may withhold that information only if “the agency reasonably foresees that disclosure would harm an interest protected by [the] exemption” or if “disclosure is prohibited by law.” Id. §552(a)(8)(A). Upon receiving a request for information, agencies have 20 business days to determine whether to comply with such requests and to notify the requester of its determination. Id. §552(a)(6)(A)(i). Finally, the FOIA provides a private right of action that permits requesters to challenge whether an agency has improperly withheld information that must be disclosed. Id. §552(a)(4)(B). B. Factual Background The ASPCA is a non-profit organization whose mission is to “provide an effective means for the prevention of cruelty to animals throughout the United States.” (Pl.’s Statement of Material Facts and Defs.’ Response (ECF No. 56) (“SOMF”)

1-2.) To further its organizational goals, the ASPCA monitors enforcement of federal animal welfare laws, including by submitting FOIA requests to federal agencies. (See id. 12; Decl. of Tonya Woods Regarding Pl.’s Policy & Practice Allegations (ECF No. 45) (“Woods P&P Decl.”) 32 n.1.) As relevant to this lawsuit, the ASPCA submitted 76 FOIA requests to the Agencies between February 2016 and January 2019. (SOMF 32.) These requests sought information related to the Agencies’ administration and enforcement of the Animal Welfare Act, 7 U.S.C. §§2131 et seq. (“AWA”), which is the primary federal statute governing the humane treatment of animals by commercial entities, such as dealers and breeders. 1. The Agencies’ Application of FOIA Exemptions 4 and 51 One type of record that the ASPCA repeatedly requested was annual license renewal applications submitted to APHIS by animal dealers, known as Form 7003. When producing these records to the ASPCA, the Agencies invoked FOIA Exemption 4 to redact information submitted by the dealers regarding their revenue, the number of animals they sold, and their annual license fee, which is calculated based on a dealer’s revenue. (Woods Decl.

 
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