Whether a forerunner to this case, We The People, et al. u. United States, 2005 U.S. Dist. LEXIS 20409 (D.D.C. 2005) aff 'd 485 F.3d 140 (2007, D.C. Cir.) was fully, fairly and completely litigated given that Court 's decision not to consider the historical scope and purpose of the Petition Clause but, instead, to rely on two inapplicable cases (.Minnesota v. Knight, 465 U.S. 271 and Smith v. Arkansas, 441 U.S. 463) in concluding government was not obligated to respond to the organization 's Petitions for Redress.

And, whether the other forerunner, United States v. We The People, et al., 529 F. Supp. 2d 341 (N.D.N.Y. 2007) aff 'd 517 F.3d 606 (2d Cir., 2008) (Schulz 1) was fully, fairly and completely litigated given that Court 's decision to avoid Defendants ' Petition Clause argument altogether and instead declare the Withholding Petition was subject to penalty.

And, if not fully, fairly and completely litigated, whether the Court should vacate the Summary Order below and the final decisions and judgments in said forerunners and remand to the D.C. Circuit in light of District of Columbia v. Heller, 554 U.S. 579 and Borough of Duryea v. Guarnieri, 564 U.S. 379.

Whether the forerunners to this case were fully, fairly and completely litigated