Plaintiffs reply to motion to uphold lower court’s verdict

Plaintiffs have standing.

Under Federal Rule of Civil Procedure 8(a), complaints need only provide a
“short and plain statement” regarding jurisdiction and claims. To survive a motion
to dismiss, a complaint needs only to contain sufficient factual matter, accepted as
true, to “‘state a claim to relief that is plausible on its face.’” Ashcroft v. Iqbal, 556
U.S. 662, 678 (2009) (citation omitted).

Please click on the link below for the full document.

D.21 Reply Br. (September 15, 2016)