1. Whether by establishing a pyramid scheme, the Government can shortcut its burden of proving the necessary elements of conspiracy to commit mail fraud and securities fraud, including whether each defendant acted with an intent to defraud?

2. Whether the instructions and the definition of pyramid scheme are impermissibly vague and abstruse, which will permit the Government to arbitrarily bring charges and convict participants in multi-level marketing companies?

3. Whether the Sixth Circuit's opinion directly conflicts with the Court's recent decision in Glossip v. Oklahoma, 604 U.S. 226, 248 (2025), and whether the Sixth Circuit misapplied Napue in allowing the Government's knowing failure to correct false evidence to go unaddressed?

Whether the Government can establish a pyramid scheme by shortcutting its burden of proving conspiracy elements and intent to defraud, and whether jury instructions defining pyramid schemes are impermissibly vague