The Texas Supreme Court's decision in Boeing Company v.
Paxton, 466 S.W.3d 831 (Tex. 2015), changed the interpretation
of the Texas Public Information Act (the "Act"), Tex.
Government Code §§ 552.001-.353, by reading the plain
language of the Act to permit private entities doing business with
governmental entities to invoke Section 552.104's disclosure
exception for "information that, if released, would give
advantage to a competitor or bidder." Tex. Gov't Code Ann.
§ 552.104 (West 2012). Prior to Boeing, the Texas
Attorney General had consistently interpreted section 552.104 to
apply only to a governmental entity's interest in remaining
competitive in the marketplace. See Tex. Att'y Gen.
ORD-592 (1991). The Attorney General had previously only applied
the exception when it was raised by a governmental entity, not when
a private company whose information was the subject of a request
tried to assert the exception. As a result of Boeing,
however, the Texas Attorney
