In In re Crawford, 194 F.3d 954 (9th Cir 1999), cert denied sub nom. Ferm v. United States Trustee, 528 U.S. 1189 (2000), a lay preparer of bankruptcy petitions objected to a statutory requirement of 11 U.S.C. 110 (c) that he place his identifying Social Security number on court papers. The Ninth Circuit recognized a right of informational privacy in relation to a Social Security number, which was a conditional right to be weighed against the governmental interest (194 F.3d at 959). It opined that the threat of identity theft was not an immediate harm, but one remote in time and place and to be undertaken by a nongovernmental actor and that--unlike disclosure of HIV status, sexual orientation, or genetic makeup--a Social Security number "is not inherently sensitive or intimate information, and its disclosure does not lead directly to injury, embarrassment or stigma" (194 F.3d at 959-960). It held a sufficient justification for the requirement could be found in the legislative purpose and bankruptcy's special interest in public access to judicial proceedings (194 F.3d at 960).