responsibility for exercise of prosecutorial discretion, but “must notify ICE whether it intends to prosecute the action. If the U.S. Attorney’s Office declines to prosecute or intends to proceed with a civil denaturalization action, or if the U.S. Attorney’s Office wishes to negotiate a plea to a different offense, it must notify ICE and OIL.”280 It is OIL attorneys (and ICE attorneys detailed to OIL) who litigate civil denaturalization cases, but the U.S. Attorney’s Office “may choose to assume primary or exclusive responsibility for litigating any civil denaturalization case.” While OSI continues to handle all actions targeting Nazi persecutors, “ICE and OSI share joint investigative authority regarding non-Nazi era human rights violator denaturalization cases.”281 In civil cases, the MOU provides that the INS is responsible for preparing a referral packet, including an Affidavit of Good Cause and an indication of the INS point of contact for litigation assistance, and referring to OIL all actions seeking revocation of naturalization under INA § 340. INS must also detail to OIL no fewer than 15 attorneys to assist in litigating revocation actions in the most heavily affected judicial districts. These include the Central and Northern Districts of California, the Southern District of Florida, the Eastern and Southern Districts of New York, the Northern District of Illinois, the District of New Jersey, the Eastern District of Virginia, and the Southern and Western Districts of Texas. 282 In criminal cases, the MOU directs INS to promptly notify OIL of its intention to refer a case for prosecution under 18 USC § 1425. The case will then be referred to the appropriate INS official for preparation and referral to a U.S. Attorney.283 Clearly, the sheer U.S. bureaucratic power trained on denaturalizations has increased greatly since 2000. That expanded reach would be soon be put to use in two recent, large-scale denaturalization efforts: Operation Janus and Operation Second Look. Operation Janus Operation Targeting Groups of Inadmissible Subjects (OTGIS), begun in 2008 and framed as a counterterrorism enforcement tool, eventually became known as Operation Janus. OTGIS began when a U.S. Customs and Border Patrol (CBP) employee identified 206 individuals who had received final deportation orders but whose naturalization or permanent residency records contain a different name or birthday. These individuals were specifically targeted because they came from “special interest countries,” also defined as, “countries that are of concern to the national security of the United States,” and countries bordering them.284 Operation Janus seems to have broken with previous executive branch practice in its scrutiny of digitized bulk data for the purposes of investigating cases for possible denaturalization. No other operation employing these tactics, whether for counterterrorism enforcement, immigration enforcement, or some other reason, is known to exist. The investigation following CUSA II. Denaturalization: A Radical Measure in the Hands of Zealots 67