Is prior salary a factor other than sex? If so:

Whether the Equal Pay Act intends prior salary, as a "catchall exception," to be excluded from bona fide job related systems and the other three statutory exceptions.

Whether the Petitioner's Seventh Amendment right to a jury trial was violated when the Fourth Circuit misapprehended summary judgment standards in light of Supreme Court precedent.

Whether and under what circumstances prior salary may constitute 'any other factor other than sex' under the Equal Pay Act