The Food and Drug Administration (FDA) (defendant) issued a notice of proposed rules governing food labels. The administrative record consisted of over 32,000 pages of testimony, in addition to thousands of exhibits. The FDA issued tentative final orders and took public comment on the orders. There were 1,000 pages of objections to the proposed rules and 20,000 other letters filed in the proceeding. After the public comment period ended, the FDA commissioner resigned. Alexander Schmidt was appointed commissioner. Within 13 days of being sworn in, Schmidt signed final regulations on food labels in the proceeding. The final food labeling regulations were accompanied by formal findings. In Schmidt’s first two weeks as EPA commissioner, he signed 14 regulations, 13 proposed regulations, and six notices. The National Nutritional Foods Association and others (plaintiffs) challenged the food labeling regulations on the ground that there was no way Schmidt could have reviewed the entire administrative record before signing the final regulations, particularly in light of the many other actions Schmidt took in his first two weeks as commissioner. The challengers sought, among other things, to take testimony from Schmidt explaining the decision with respect to the food labels.