Azad Alamgir Kabir v. WebMD LLC

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,” dispropor­ tionately impacting minority communities and small inventors.

Whether Federal Rule of Civil Procedure 5(d)(3)(B)(i) is unconstitutional as applied to a geo­ graphically distant pro se inventor in a complex intel­ lectual property case, where the mandatory use of pa­ per-filing creates a “procedural vacuum” that allows institutional defendants to exploit timing asymme­ tries and moot opposition before it is even docketed.

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 ac­ cess, violates the Due Process Clause of the Fifth Amendment by denying individual inventors “mean­ ingful access” to the courts in distant, defendant-controlled forums.

Whether a venue and procedural regime that permits institutional defendants to consolidate litiga­ tion in forums that effectively “blockade” pro se evi­ dence and expert analysis through administrative la­ bels of “abuse” creates an irreparable structural harm that cannot be remedied on standard appeal.

Whether federal courts must consider accessto-courts consequences and the disparate impact on