1. Does it violate the First Amendment for the
Securities and Exchange Commission to impose a
requirement that any party with whom it settles
must agree to a lifelong prior restraint barring any
statement, however truthful and whenever and
however expressed, that even suggests that any
allegation in a Securities and Exchange Commission
Complaint is insupportable?

2. Does the Securities and Exchange
Commission violate the Due Process Clause when it
requires that any party with whom it settles must
sign an SEC-drafted Consent Form waiving his due
process rights and agree to a lifelong prior restraint
barring any statement, however truthful and
whenever and however expressed, that even
suggests that any allegation in a Securities and
Exchange Commission Complaint is insupportable?

3. Is a final judgment entered by a United
States District Court which includes an
unconstitutional lifetime ban on any statement,
however truthful and whenever and however
expressed, that even suggests that any allegation in
a Securities and Exchange Commission Complaint is
insupportable, void, and therefore subject to review
under Rule 60(b)(4)?

Does the SEC's requirement of a lifetime gag order in settlements violate the First Amendment?