Case 1:14-cv-09763-VM Document 44 Filed 08/28/15 Page 27 of 35 the risk of harm •substantial.• . ··argues,... - F\1rthermore, li •• -• as Merrill (See Pl. Mem. at 19; Pl. Reply Mem. at ll, 21-22.) Therefore, the Court finds that the Government has not demonstrated targets of a good national reason to security believe that investigations their behavior to evade detection, potential will change or that disclosure of the Attachment in its entirety would create a substantial risk of one of the statutorily enumerated harms. The Court's ruling here is consistent with the Court's prior decisions relating to the NSL issued to Merrill. First, the present challenge can be factually distinguished from Doe III and ~· In Doe III, this Court found that the Government had carried its burden of reason to including keep the confidential. ongoing, of ~~ identity In Doe IV, of NSL letter and the recipient good Attachment, and target, while the investigation remained the court found that specific information in the Attachment scope the showing a could be disclosed: information that the both material NSL statute within identifies the as permissible for the FBI to obtain through the use of NSLs, - 27 -