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Privacy is a word we hear frequently in today's technologically advanced society. From Google Maps documenting every street in the nation to smartphones sharing locations automatically, privacy concerns abound. In fact, a recent Consumer Reports study found that over seventy percent of respondents said they were very concerned about the sharing of their personal information.' Nevertheless, these worries seem to have fallen on deaf ears as displayed by the United States Supreme Court's recent decision, Federal Aviation Administration v. Cooper. The Court in Cooper ruled that although sharing confidential records without a citizen's permission violated the Privacy Act of 1974 (Privacy Act), it did not result in pecuniary loss and therefore was not recoverable. This decision, combined with the Court's most recent interpretation of the Privacy Act's civil remedies provision in Doe v. Chao, leaves the Privacy Act powerless to stop government agencies from sharing personal and sensitive information without recourse or consequence.

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