Whether—in line with holdings from the Second, Third, Fourth, Fifth, Sixth, Eighth, Ninth, and Tenth Circuits—a motion for Rule 11 sanctions may be granted only if the motion is served more than 21 days before filing, as required by Rule 11(c)(2); or whether a Rule 11 motion may instead be granted despite the movants' failure to serve the motion prior to filing, as the Seventh and Federal Circuits have held.

Whether a motion for Rule 11 sanctions may be granted despite the movants' failure to serve the motion prior to filing