One such fundamental right, at issue in this case, is the right to vote. Voting is one of the foundational building blocks of our democratic society, and that the Constitution firmly protects this right is “indelibly clear.”100 All citizens of the United States have a constitutionally protected right to vote.101 And all citizens have a constitutionally protected right to have their votes counted.102 With these background principles firmly rooted, the Court turns to the merits of Plaintiffs’ equal-protection claims. The general gist of their claims is that Secretary Boockvar, by failing to prohibit counties from implementing a noticeand-cure policy, and Defendant Counties, by adopting such a policy, have created a “standardless” system and thus unconstitutionally discriminated against Individual Plaintiffs. Though Plaintiffs do not articulate why, they also assert that this has unconstitutionally discriminated against the Trump Campaign. As discussed above, the Court will address Individual Plaintiffs’ and the Trump Campaign’s claims separately. Because Individual Plaintiffs premised standing on the purported wrongful cancellation of their votes, the Court will only analyze whether Defendants have impermissibly burdened Individual Plaintiffs’ ability to vote. Further, the Court will consider two issues raised by the Trump Campaign; the first being whether it has stated a valid claim alleging discrimination relating to its use of poll-watchers, and the second being whether 100 101 102 Reynolds v. Sims, 377 U.S. 533, 554 (1964). Id. (citing Ex parte Yarbrough, 110 U.S. 651 (1884)). Id. (citing United States v. Mosley, 238 U.S. 383 (1915)). - 27 -