Whether a party waives the defense of lack of personal jurisdiction if available but omitted from its first court filing in a motion to set aside a default

QUESTION PRESENTED Rule 12(b) of the Federal Rules of Civil Procedure identifies four specific defenses, including lack of personal jurisdiction, which are waived if available to a party but omitted from a motion made by that party before answer. See Fed. R. Civ. P. 12(h)(1)(A). The question presented is: Whether a party waives the defense of lack of personal jurisdiction if available but omitted from its first court filing in a motion to set aside a default.