While the specific recommendations of the OIG report did not make reference to potential denaturalization for any of those who naturalized under CUSA, information gathered by the Open Society Justice Initiative in the preparation of this report suggests that attorneys working for the Department of Justice and INS began scrutinizing CUSA cases for potential denaturalization actions in the years following its implementation. As of July 1998, “INS General Counsel had reviewed 4,269 cases for possible revocation. Of those, 2,686 had been deemed appropriate for revocation. . . . A working group comprised of staff from the General Counsel’s Office, from the Office of Immigration Litigation (OIL) of the Department’s Civil Division, and from U.S. Attorneys’ offices identified which cases should be brought first.” From the original pool of 2,686 cases, 110 cases were referred to OIL for possible litigation. OIL in turn referred 68 of those cases to U.S. Attorneys’ offices, and those offices authorized 27 cases for denaturalization litigation. According to the OIG report, four people had been denaturalized at the time.275 While the Justice Initiative did not investigate the public resources devoted to the CUSA investigation, clearly the effort would have involved considerable expenditures. A short-lived effort to create an administrative denaturalization procedure. Under the Immigration Act of 1990, power over naturalization was shifted from the courts to the attorney general, including the power “to correct, reopen, later modify, or vacate an order naturalizing the person.”276 In Gorbach v. Reno (2000), a class action case brought in Washington state in 1998 during the height of the CUSA denaturalization operation, the Ninth Circuit Court of Appeals ultimately enjoined administrative denaturalization. The fact that the nationwide injunction has held demonstrates, perhaps, a wide recognition that the 1990 Act did not aim to establish administration jurisdiction to denaturalize Americans when it transferred naturalization power from the courts to the Attorney General. However, the issue has never come before the Supreme Court and the act itself has never been amended specifically to preclude administrative denaturalization. In contrast, Canada recently ended fast-tracked administrative denationalizations and reversed hundreds of decisions rendered under its previous scheme. The Office of Immigration Litigation. The CUSA cases may have been some of the first cases litigated by what would become the OIL District Court Section (OIL-DCS), a new unit specializing in civil denaturalization within the Department of Justice’s Civil Division. OIL-DCS was established in 2008. In 2017, a new unit under OIL-DCS called the National Security and Affirmative Litigation Unit was established to handle “high-profile denaturalization cases involving known or suspected terrorist aliens in immigration detention.”277 On January 22, 2000, U.S. Attorney’s Offices, INS (now ICE), and OIL entered into a Memorandum of Understanding (MOU) 278 that covered the “parties’ mutual responsibilities in denaturalization actions.” 279 Under the MOU, the U.S. Attorney’s Office has primary 66 UNMAKING AMERICANS