Case 1:14-cv-09763-VM Document 44 Filed 08/28/15 Page 13 of 35 possibility. The upholding of nondisclosure does not require the certainty, or even' the imminence of, an enumerated harm, but some reasbna:ble likelihood must be shown. The Government aclmo1!1ledges that while the "reason to believe" standard in subsection 3511 (l:>) unquestionably contemplates a qeferential standard of review, in no way does it f¢reclose a court from evaluating the reasonal:>leness of the FBI's judgments. ±..9..:. at 875. The Second Circuit then addressed whether courts could be required to apply a conclusive presumption (absent bad faith) to the FBI certification: While the court will normally defer to the Government's considered assessment of ~ disclosure in a particular case may result in an enumerated harm related to such grave matters as international terrorism or clandestine intelligence activities, it cannot, consistent with striQt scrutiny standards, uphold a nondisclosure requirement on a conclusory assurance that such a likelihood e~ists. Id. at 881. Instead, the Government must "at least indicate the nature of the apprehended harm and provide a court with some basis to assure itself that the link between disclosure and the risk of harm is substantial.• ££.:_ at 881 (emphasis added) . Finally, as Circuit stated to that the the third "keyed to the information sought by an investigation the Second statutorily enumerated harms necessarily authorized requirement, same NSL, standard i.e., relevant to protect against - 13 - that are governs to an international