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On March 26, 2013, TSA proposed a rule regarding passenger screening using advanced imaging technology after a federal appeals court ordered the agency to do so in 2011. In conducting this rulemaking, however, TSA has flouted the 2011 court order by proposing a rule that does not comport with the federal law that governs agency rulemaking. TSA has also failed to demonstrate that the proposed rule’s benefits exceed its considerable costs.