are two categories of information that may fall within Exemption 2’s ambit— “Low 2” and “High 2.” Low 2 materials include rules and practices regarding mundane employment matters such as parking facilities, lunch hours, and sick leave, which are not of “genuine and significant public interest.” See Rose, 425 U.S. at 363, 96 S.Ct. 1592 (citing S.Rep. No. 813-89, at 8 (1965)); id. at 369, 96 S.Ct. 1592; Hardy v. Bureau of Alcohol, Tobacco & Firearms, 631 F.2d 653, 655 (9th Cir.1980). The High 2 exemption protects more sensitive government information. This category applies to “internal personnel rules and practices,” disclosure of which “may risk circumvention of agency regulation.” Rose, 425 U.S. at 369, 96 S.Ct. 1592; see, e.g., Schiller v. NLRB, 964 F.2d 1205, 1208 (D.C.Cir.1992) (<HOLDING>). Only the High 2 category is at issue here. B
holding that courts will not defer to an agencys litigating position where it contradicts the agencys prior regulations rulings or administrative practice holding that courts must defer to executive branch regulations implementing statutes so long as agencys regulation is based on a permissible construction of the statute holding that purely factual material may be withheld from disclosure under exemption 5 if that material would expose the deliberative process of an agency holding an agencys litigation strategy does qualify as high 2 material because its disclosure would risk circumvention of statutes or agency regulations holding that an agencys interpretation of its own regulations is entitled to deference