National Council of Teachers, Quality, Inc. v. Curators of the University of Missouri, WD76785 (Mo. App. August 26, 2014) held that the University properly denied a Sunshine request for a copy of teachers’ copyrighted syllabi, finding such was exempt from disclosure by the Federal Copyright Act. This case creates new ambiguity regarding when and when not to provide copies of copyrighted material in response to a Sunshine request creating a need for new caution.