Case 1:20-cv-03325-AT Document 43 Filed 05/05/20 Page 11 of 30 presidential candidate receives more votes, then more delegates pledged to that candidate are entitled to participate in the Convention. Id. ¶ 33.3 The process of selecting individual delegates is a complicated one, involving Democratic Party rules and priorities, and it is difficult to know in advance if any individual delegate candidate will make it to the Convention. Id. ¶ 35. Defendants are correct, therefore, that the Democratic presidential primary election would not have determined whether any of Delegate Plaintiffs would, in fact, serve as Convention delegates. Def. Opp. at 12. But under current rules, the only way for any New York delegate to participate in the Convention is if their presidential candidate receives a qualifying vote share. So holding the primary would provide Delegate Plaintiffs with an opportunity—indeed, the only opportunity—to compete for the chance to become Convention delegates. That Delegate Plaintiffs’ rights are tied to those of Yang and other presidential candidates does not diminish Delegate Plaintiffs’ importance, or their standing to sue when their ability to run—which rises and falls on their presidential candidates’ viability—is threatened. Accordingly, Plaintiffs and Plaintiff-Intervenors have established that they have standing to bring this suit. II. Sovereign Immunity Under the United States Constitution, states “retain the dignity, though not the full authority, of sovereignty.” Alden v. Maine, 527 U.S. 706, 715 (1999). For that reason, the Eleventh Amendment to the Constitution, incorporating the longstanding doctrine of “sovereign immunity,” bars federal lawsuits against a state unless (1) the state unambiguously consents to be 3 It is also possible—though not necessary—for delegates to appear on the ballot in their own name. Brehm Decl. ¶ 33. But the votes that the delegates receive for themselves determine only the “order” of delegates within a presidential candidate’s slate. Id. ¶ 35. The number of a candidate’s committed delegates that are sent to the Convention is determined only by the votes for the presidential candidate. Id. ¶ 33. 11