1. In light of the "plausibility" standard established by
this Court in Bell Atlantic Corp. v. Twombly , 550
U.S. 544 (2007) and Ashcroft v. Iqbal , 556 U.S. 662
(2009), where a plaintiff has not made any factual
allegations regarding access, are conclusorystatements that "striking similarity" exists betweentwo works insufficient to plead a claim of copyrightinfringement, or do such allegations meet thepleading standard, as the Ninth Circuit held in this
case?

2. Even if a pleading of striking similarity is
permissible absent any pleading of access, areplaintiffs required to plead reliable evidence ofcopyright ownership and evidence as to what workis allegedly protected by that copyright (includingofficial copies of the work s' copyright registrations
and copies of the deposit materials submitted to theCopyright Office) in light of Fourth Estate Pub.
Benefit Corp. v. Wall-Street.com, LLC ("Fourth
Estate "), 139 S. Ct. 881 (2019), or are such materials
not required to meet the pleading standard, as theNinth Circuit held in this case?

3. On a motion to dismiss, are a defendant's copyrights
prima facie evidence of the copyrights' validity, the
ownership of the work, and the work's independentcreation, and thus sufficient to bar a pleading ofstriking similarity, or is consideration of suchmaterials inappropriate before summary judgmentor trial, as the Ninth Circuit held in this case?

Whether conclusory statements of 'striking similarity' are sufficient to plead copyright infringement under the 'plausibility' standard