In the case of Mobay Chemical Corp. v. Costle, Administrator, United States Environmental Protection Agency (1978), Mobay Chemical Corporation challenged the EPA's decision to disclose information about its pesticide products under the Freedom of Information Act (FOIA). The company argued that this violated their rights as it included trade secrets and confidential business information. However, the Supreme Court ruled in favor of the EPA stating that such data could be disclosed if it was considered "emission data". This term referred to any information necessary for understanding or controlling emissions from a source into environment including production volumes and product composition details which were previously deemed proprietary by companies like Mobay. Therefore, despite corporate objections on grounds of confidentiality and potential competitive harm, public health concerns took precedence leading to increased transparency regarding chemical substances released into environment.

In the dissenting opinion for the Mobay Chemical Corp. v. Costle case, it was argued that the majority's decision to uphold EPA's data-consideration regulations under FIFRA (Federal Insecticide, Fungicide, and Rodenticide Act) is a misinterpretation of Congress' intent. The dissenting justices believed that these regulations were not consistent with either the language or purpose of FIFRA’s compensation provision which aims at encouraging manufacturers to develop new pesticides by protecting their test data from use by competitors during a certain period. They contended that allowing EPA to consider an applicant’s data in evaluating another manufacturer’s product without requiring compensation effectively nullifies this protection and discourages innovation in pesticide development. Furthermore, they disagreed with majority's view on "use" of data arguing that considering one party's test results while evaluating another party's application constitutes "use". Lastly, they criticized majority for deferring excessively to administrative interpretation where statutory language is clear and unambiguous.