Mulling it over, I can actually think of a range of cases where "specific identifier" would block intuitively acceptable records demands.
@normative Nonsense. They have different meanings. Add in the "based on" language throughout the bill and you're a degree away from selector
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@emptywheel Well, I think the INTENT is that (say) phone #, billing address, credit card, or name might all (or in combo) ID a facility -
@normative Or intent of those who laid nice leg record (ignoring explicit IC definition of bulk collection) which only useful in Art III?
End of conversation
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