A party challenging the validity of an issued patent in district court or in an inter partes review (“IPR”) proceeding before the Patent Trial and Appeals Board (“PTAB”) bears the burden of proving invalidity. 35 U.S.C. 8§ 282, 316(e). To anticipate a claim of an issued patent, a prior art printed publication must disclose and enable said claim. Seymour v. Osborne, 78 U.S. (11 Wall.) 516, 538 (1870); Amgen Inc. v. Hoechst Marion Roussel, Inc., 314 F.3d 1318, 13854 (Fed. Cir. 2008) (“a non-enabled disclosure cannot be anticipatory (because it is not truly prior art)’). The questions presented are:

1. Should printed publications be presumed to be enabling when a party challenging the validity of issued patent claims asserts that a printed publication is anticipatory prior art, such that the burden of proving that the printed publication is nonenabling lies with the patentee?

2. Should the holding in Rasmusson v. SmithKline Beecham Corp., 413 F.3d 1318, 1826 (Fed. Cir. 2005), that “proof of efficacy is not required in order for a reference to be enabled for purposes of anticipation,” be vacated or significantly narrowed?

I. Whether Federal Rule of Evidence 415 overrides Rule 403’s requirement to balance the probative value of temporally remote propensity evidence against its prejudicial effect before such evidence can be admitted?

II]. Whether Federal Rule of Evidence 413(d) authorizes the admission of temporally remote propensity evidence that the defendant committed the “crime” of “sexual assault” when the alleged prior act did not constitute a crime or a sexual assault?

III. Whether Federal Rule of Evidence 404(b)(2) permits the admission of “modus operandi” or “corroboration” evidence of prior “bad acts” without establishing a non-propensity purpose of the evidence, such as identity, absence of mistake, or another enumerated exception in Rule 404(b)(2)?

Under 18 U.S.C. § 1847, a person is guilty of health care fraud if he willfully executes, or attempts to execute, a scheme to obtain money or property from a health care benefit program “by means of false or fraudulent pretenses, representations, or promises… .” In a so-called “upcoding” case like this one, the allegedly false representations are the numeric codes attached to a healthcare provider’s claim for insurance reimbursement. The selection of these codes, which represent medical services and procedures, are governed by a complex set of rules promulgated by the American Medical Association (“AMA”).

The question presented—which has divided six circuits—is:

When an allegedly false statement is premised on an ambiguous rule open to multiple reasonable inter- pretations, can the government secure a defendant’s conviction merely by persuading a jury that its preferred interpretation is “better”?

(1)

In Natl Inst. of Family & Life Advocates v. Becerra, 585 U.S. 755, 768 (2018) (NJFLA), this Court rejected the professional speech doctrine, which gave government “unfettered power to reduce a group’s First Amendment rights by simply imposing a licensing requirement.” Yet in the seven years since, “the division between speech and conduct has not been evenly applied throughout the country, particularly when it comes to licensing schemes that determine which individuals can speak about certain topics.” Richwine v. Matuszak, 148 F.4th 942, 953 (7th Cir. 2025) (citing conflicting decisions from federal courts of appeals). The decision below deepened that acknowledged circuit split. The questions presented are:

1. Whether a burden on speech must be incidental merely because it is imposed by an occupational licensing law.

2. Whether a law that imposes incidental burdens on speech must satisfy intermediate scrutiny.

’ 4. Does the deprivation of self-representation/access to courts, with the purpose of preventing challenges to rights violations, entitle the victim, through established law, to . review of the disqualified challenges and or dismissal of criminal charges and release from custody?

5. Does established law protect an enforce rights violated through vague, ambiguous,

conflicting state legislation, non-elected appointed officials and prolonged ex—parte

influence/inadmissible evidentiary support and arguments?

6. Is this court obligated to revisit, under stare decisis, impact of actuality, highest level of . controversy, the internal constitutional conflict between the 9t and 14t* Amendments for

vague and ambiguous wording in the 9 Amendment, violating International law, when the

application results in arbitrary detention perpetrated by non-elected, appointed judges and

assistant prosecutors falsely claiming a lawful authority?

2

Michael Saabght . THE Cou®T:– we 40 tiengh all this | all these other

Counts ive dismiscect . They’ve gone. okay, “the on ly reason took. a plea ©

because Ft honer believed she would get a lesser sentevce -b 4 counts

laased on Judge S., Michael Seatoyig tts statements whicin Rrhoner Velied on —

Yo taking a plea deal. See Labler v. Cooper, Sb US. 156 , 13255,ch. ISG 182 L.

ee 7d 348 ( 2012 explain “the sole advantage a defendant would have,

Cewed uncer the Plea is 4 lesser sentence. ‘Cemplasis added)’ ©) Whether on August id, 2021 , Judge J. Michael Seabniyint made Nte own order

a an ctempt 1 cure a substantial rig nt Violafcn that Retrhoner did not

a Proceect With a change of pleq by video tov Unitecl Stertess v. Sulliien )

. No. 2i “CoO re “SMS—- KTM CECE No.&) on Tuly 20,2024 written om August

(2024 ] ECE th IS j which was done iD days ater Petitions; Filecd her

Motion Yo Withdavaw My Plea As A Violahem of My United Settles Constituhonee| Rignis Amendment One , Fourth, Sati, Fourkenth; Bresch of Conhact; Proseurtoviat Misconduct, fed. R. Cam. P. Rule i! Cee No. ) July 4 2021) Ketihoner should have been allowed -» Withdiaw her plea?

(3) Whether Petites ine Shown Prejuclice fom the Uae ofthe video aid teleconference dunn Retrhone cna of plat, as Pethener would not rave proceected with Guilty plea She waited tappeay in person ifthe

| disc cowt made more of-detailect findings tor the need of feteconference’ , (See United Sicttex ae Domung de? Bein eZ , ALUS.A485 12454 LBB, (SAL. Edd. 2d (154 C2004) “ The pownr.. . tS to CAQUIre Wihetner tie Lewor]| .- would have made thediterence required ley the standard of veasonalole- probaloility. and ner piea Should vVewe been allowed te withdraw?

(4) Whether Fthover should Wve een clole to Withdiaw ner pie wVhen she Claimed her innocense 4p identity thett as she WAS Appro rect 40 Open up a corporate credit carci fr the non ~piohtcoiportion loy Chairman Levon Onar who dial two moths ater approving corpoutl> account So thee Wits no conch Grewict OF identity theft and Retthoner shoulda have been allouet +o withhdvaw her plea? | |

(5) Whether <stahte of limitahons 16 a yunsdictora| requirement that cannet ke waued by a pier agicoment as the allegzt came took place. on Mach af,

20IZand was chayssd A ycrus later, +he slettute oHimitezthoms iS a

janedichone| requirement thet cannot las waived, aNd Convichen should be /

overtumed gon &. Sand & Grewel Co. v. United Stes, 652 U.S 130 (33-24,

(2-8 S.Ch 460,164 1.Ed. 2d SAI ( 2€08)) 7 |

1. Whether 18 U.S.C. § 922(¢)(1), the statute permanently prohibiting possession of firearms by persons convicted of a crime punishable by imprisonment for a term exceeding one year, 1s constitutional under the Second Amendment.

2. Whether 18 U.S.C. § 922(g)(1) 1s unconstitutional because it exceeds Congress’s authority under the Commerce Clause as applied to intrastate possession of a firearm.

1 This first question in this petition, regarding whether the Eleventh Circuit correctly holds § 922(g)(1) constitutional without engaging in an as-applied analysis and categorically barring felons from possessing firearms, 1s also raised in other petitions, including Jones v. United States, No. 25-5820 (distributed for conference of Nov. 14, 2025). The question of whether § 922(g)(1) 1s subject to an as-applied challenge is also similar to—but distinct from—other petitions that turn on the availability and scope of an as-applied challenge. See, e.g., Howard v. United States, No. 25-5220 (distributed for conference of November 21, 2025) (“Whether 18 U.S.C. §922(¢)(1) comports with the Second Amendment as applied to a defendant whose most serious prior felony conviction is drug trafficking?’); Vincent v. Bondi, No. 24-1155 (distributed for conference of November 21, 2025) (“Whether the Second Amendment allows the federal government to permanently disarm Petitioner Melynda Vincent, who has one seventeen-year-old nonviolent felony conviction for trying to pass a bad check.”).

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