A request has to be by a "person", not necessarily a national or citizen of the 
U.S., as far as I see in the statute. This came up as an issue during the 
Reagan Presidency because the Cold War-era U.S.S.R. reportedly made FOIA 
requests and I think they resolved it by the U.S. Attorney General of that time 
announcing that any agency refusing any FOIA request would have its position 
defended, but that may not apply any more.

By the way, anyone copying either of my URLs above from a quoted part of an 
email should be sure to get the entire URL, not just the part that is linked, 
and edit out the quote-signifying "> " strings.
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