1. “Whether the systematic denial of Electronic Case Filing (ECF) access to pro se litigants violates the Equal Protection component of the Fifth Amendment by creating a discriminatory two-tiered system that grants represented parties instantaneous docketing while subjecting self-represented litigants to a 5-to-12-day ‘paper-filing blockade,’ disproportionately impacting minority communities and small inventors.”
2. “Whether Federal Rule of Civil Procedure 5(d)(3)(B)(i) is unconstitutional as applied to a geographically distant pro se inventor in a complex intellectual property case, where the mandatory use of paper-filing creates a ‘procedural vacuum’ that allows institutional defendants to exploit timing asymmetries and moot opposition before it is even docketed.”
3. “Whether the venue doctrine articulated in TC Heartland LLC v. Kraft Foods Group Brands LLC, 581 U. S. 258 (2017), when combined with restrictive local procedural regimes and unequal electronic access, violates the Due Process Clause of the Fifth Amendment by denying individual inventors ‘meaningful access’ to the courts in distant, defendant-controlled forums.”
4. “Whether a venue and procedural regime that permits institutional defendants to consolidate litigation in forums that effectively ‘blockade’ pro se evidence and expert analysis through administrative labels of ‘abuse’ creates an irreparable structural harm that cannot be remedied on standard appeal.”
5. “Whether federal courts must consider access-to-courts consequences and the disparate impact on minority pro se litigants—as identified in empirical studies of the ‘Civil Justice Gap’—when applying discretionary procedural rules that burden individual inventors.”
6. “Whether the use of Generative Al as a ‘force multiplier’ to bridge the ‘manpower gap’ for pro se litigants constitutes a protected form of ‘meaningful access’ to the courts, and whether striking a primary opposition in its entirety due to a single, noncritical AI-generated ‘hallucination’—rather than allowing for curative measures—violates the Due Process Clause of the Fifth Amendment as a grossly disproportionate terminal sanction.”
