What does 'personal privacy' mean under FOIA, Exemption contained in 5 U. S. C. §552(b)(7)(C).?

In a recent development, the U.S Supreme Court in the case between FEDERAL COMMUNICATIONS COMMISSION ET AL. v. AT&T INC. ET AL. has held that, "corporations do not have “personal privacy” for the purposes of Exemption 7(C)" of 5 U. S. C. §552, other wise known as the Freedom of Information Act. The case arose from AT&T suing the Federal Communications Commission, which agreed to release information to CompTel, a trade association, upon a FOIA request for documents AT&T had provided to the Federal Communications Commission Enforcement Bureau during an investigation of that company.

"The Bureau found that Exemption 7(C) applied to individuals identified in AT&T’s submissions but not to the company itself, concluding that corporations do not have “personal privacy” interests as required by the exemption. The FCC agreed with the Bureau, but the Court of Appeals for the Third Circuit did not. It held that Exemption 7(C) extends to the “personal privacy” of corporations, reasoning that “personal” is the adjective form of the term “person,” which Congress has defined, as applicable here, to include corporations."

This decision by the U.S. Supreme Court is commendable, considering the fact that the court has, just a year ago expanded the power of corporations in the CITIZENS UNITED v. FEDERAL ELECTION COMMISSION case, wherein it struck down the restriction on 'corporations' to spend on political campaigns. (On a side note, if one reads the Citizens United case, one is certain to fall asleep, whereas reading the headlines on the same issue makes one jump out of their seats! And, I am also confused about the decision, after I have read the primary decision itself!)

The decision of the Court in the FCC v.AT&T case is a balanced decision, wherein the Court closely examined whether corporations can have a 'personal' character, specifically under FOIA and found that, “Person” is a defined term in the statute; “personal” is not. When a statute does not define a term, we typically“give the phrase its ordinary meaning.” Some of the adjectival usages that the Court referred to include - corn and corny; crank and cranky; crab and crabbed (handwriting). The Court emphatically observed that,
"We do not usually speak of personal characteristics, personal effects, personal correspondence, personal influence, or personal tragedy as referring to corporations or other artificial entities. This is not to say that corporations do not have correspondence, influence, or tragedies of their own, only that we do not use the word “personal” to describe them."
and upheld the decision of the FCC.

It is indeed, very heartening to see that the Court still strictly interpreted FOIA and did not expand the scope of the limitations as it would have undermined the intent of the law, considering that private corporations have an increased presence in citizens' lives and not governed under FOIA, which is applicable only to Federal agencies. In the absence, of a FOIA applicable to private entities the existing limitations, serve as a balance between private interest and public interest.

Concluding the decision, the Court observed, tongue in cheek, the following:
"We reject the argument that because “person” is defined for purposes of FOIA to include a corporation, the phrase“personal privacy” in Exemption 7(C) reaches corporations as well. The protection in FOIA against disclosure of law enforcement information on the ground that it would constitute an unwarranted invasion of personal privacy does not extend to corporations. We trust that AT&T will not take it personally."