1. Whether a failure to follow federal rules relating to pay without credible explanation that results in a protected class receiving less pay than other protected classes for the same duties and responsibilities can be enough to create a genuine issue of material fact preventing summary judgment in a Title VII claim under 42 U.S.C. § 2000e-16(a).

2. Whether Tolan v. Cotton, 572 U.S. 650 (2014), is applicable to federal employee Title VII claims.

Subsidiary questions are whether the language and syntax of Title VII should be interpreted as it was under the ADEA, and whether such language bans retaliation in federal employment.

Whether a failure to follow federal rules relating to pay without credible explanation that results in a protected class receiving less pay than other protected classes for the same duties and responsibilities can be enough to create a genuine issue of material fact preventing summary judgment in a Title VII claim under 42 U.S.C. § 2000e-16(a)