1. Whether the Noerr-Pennington doctrine has been improperly expanded beyond its First Amendment moorings to insulate knowingly, recklessly, or intentionally false statements.

2. Whether the Noerr-Pennington doctrine is irreconcilable with jury findings against Respondents in this matter—all of which were premised on "appropriate standard[s] of liability" established by the state of Texas, which parallel the outward limits of First Amendment protections.

3. Whether these errors were sufficiently presented to the courts below.

Whether the Noerr-Pennington doctrine has been improperly expanded beyond its First-Amendment-protections to insulate knowingly-false-statements