Whether the Ninth Circuit has ignored this Court's well-established standards regarding per se antitrust violations and misapplied pleading standards in a complex antitrust case involving Google's market agreements

1. Whether the Ninth Circuit has ignored this Court’s well -established standards regarding per se antitrust violations, including division of markets ( United States v. Topco Assocs. , 405 U.S. 596, 610 (1972) ; Palmer v. BRG of Georgia, Inc. , 498 U.S. 46 (1990) ), profit pooling ( Citizen Publ’g Co. v. United States , 394 U.S. 131 (1969) , foreclosure of competitors from a substantial market ( Int’l Salt Co. v. United States , 332 U.S. 392 (1947) ), and price fixing ( United States v. Socony -Vacuum Oil Co., 310 U.S. 150 (1940) ), where the Second Amended Complaint plausibly alleged horizontal agreements between Google and Apple to divide markets, share profits, and foreclose competition, as corroborated by the findings in United States v. Google LLC, 20cv-3010APM (D.D.C. Aug. 5, 2024). 2. Whether a district court may stay all discovery in an antitrust case based solely on a “preliminary peek” at a pending motion to dismiss, without any showing of good cause as required by Rule 26(c) of the Federal Rules of Civil Procedure, and in derogation of the due process and equal protection rights of plaintiffs, contrary to the Ninth Circuit’s own precedent in Mach -Tronics, Inc. v. Zirpoli, 316 F.2d 820 (9th Cir. 1963) . 3. Whether this Court should resolve the conflict between the Ninth Circuit’s decision below and the District of Columbia’s decision in United States v. Google LLC, 747 F. Supp. 3d 1 (D.D.C. 2024) , which found that Google’s ii exclusive agreements with Apple and others were anticompetitive and resulted in supra competitive prices for search advertising. 4. Whether the Ninth Circuit erred in enforcing Google’s arbitration clause based on an “opt out” that was illusory in practical effect, where undisputed monopoly power left Petitioners with no viable alternative for search advertising and no evidence establi shed Google would have continued to deal with Petitioners had they opted out — contrary to the Federal Arbitration Act’s saving clause and the “effective vindication” doctrine recognized by this Court ( 9 U.S.C. § 2; Mitsubishi Motors Corp. v. Soler ChryslerPlymouth, Inc. , 473 U.S. 614 (1985) ; Green Tree Fin. Corp. -Ala. v. Randolph , 531 U.S. 79 (2000) ; Am. Express Co. v. Italian Colors Rest., 570 U.S. 228 (2013) ). 5. Whether compelling arbitration of private antitrust claims seeking legal remedies violates the Seventh Amendment right to a jury trial where such claims are “suits at common law” and do not fall within the public rights exception —especially in light of this Court’s recent holding restoring the Seventh Amendment’s scope in SEC v. Jarkesy , 144 S. Ct. 2117 (2024) (Granfinanciera, S.A. v. Nordberg, 492 U.S. 33 (1989) ; Tull v. United States , 481 U.S. 412 (1987) ). 6. Whether the district court erred in denying relief from judgment under Rule 60(b) based on newly discovered, trialproven evidence of Google’s unlawful monopoly maintenance agreements with Apple—evidence later made iii public in the federal government’s successful antitrust suit —where Petitioners could not, with reasonable diligence, have obtained that evidence earlier and where it likely would have altered the outcome (Fed. R. Civ. P. 60(b)(2), (6); Gonzalez v. Crosby , 545 U.S. 524 (2005) ; United States v. Beggerly, 524 U.S. 38 (1998) ). 7. Whether the courts below erred by denying Petitioners any opportunity for targeted discovery in a complex antitrust case where critical evidence resided exclusively with Defendants —contrary to this Court’s instruction that antitrust plaintiffs must have a fair opportunity to develop facts ( Poller v. Columbia Broad. Sys., Inc ., 368 U.S. 464 (1962) ; Hospital Bldg. Co. v. Trustees of Rex Hosp ., 425 U.S. 738 (1976) ; Eastman Kodak Co. v. Image Tech. Servs., Inc. , 504 U.S. 451 (1992) ). 8. Whether the Ninth Circuit misapplied the pleading standard under Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) and Ashcroft v. Iqbal , 556 U.S. 662 (2009) by crediting its own view of the facts and fa