Ricky Kamdem-Ouaffo, Trading as Kamdem Group v. Colgate Palmolive Co., et al.

Whether 28 U.S.C. § 1447(d)’s appellate-review bar permits a court of appeals to deny review of Rule 60(b)(4) and Rule 60(b)(6) motions in separate original federal patent and fraud-on-the-court actions by giving cross-suit preclusive effect to an unreviewable remand order, despite the twelve-circuit consensus that unreviewable remand orders and remand-related jurisdictional findings carry no such preclusive effect, and this Court’s decision in Royal Canin U.S.A., Inc. v. Wullschleger, recognizing that a post-removal amended complaint may establish federal jurisdiction going forward.

Whether a court of appeals may treat a challenge to a state court’s total lack of subject-matter jurisdiction as waived or forfeited, thereby permitting 28 U.S.C. § 1447(d) to shield state-court orders entered during the mandatory 28 U.S.C. § 1446(d) removal stay—orders this Court’s precedents treat as “absolutely void,” ultra vires, and coram non judice.

Whether Article III and the Fifth Amendment’s Takings Clause permit lower federal courts to expand 28 U.S.C. § 1447(d)’s remand-review bar into a cross-suit shield that forecloses merits adjudication and appellate review of independent original federal patent, trade-secret, and fraud-on-the-court claims, where that expansion allegedly deprived Petitioner of an Article III forum and caused the < uncompensated loss of protected trade-secret and patent-related property interests.