80. Third, Defendants Stapleton and Mangan's exclusive focus on ballots conveyed in person is discriminatory as applied to Plaintiffs, who face geographic, socio-economic and racism-based barriers. 81 . Irregular mail service on reservations fiequently makes it difficult to collect and retum ballots via mail in sufficient time to be counted. 82. As a consequence, Plaintiffs are more likely to collect ballots and convey them in person than by mail-putting them squarely in BIPA's crosshairs. 83. And fourth, BIPA creates a risk that Native American communities are more likely to be harmed by BIPA's enforcement scheme. 84. BIPA also requires that Defendant Mangan's office investigate all individual citizens' complaints that a ballot collector has violated 1 1 1(2)(a) ("Upon the submission BIPA. Mont. Code Ann. $ 13-37- of a written complaint by any individual, the commissioner shall investigate any other alleged violation of the [BIPA]"); (there is a link to an individual complaint form and email address to transmit the complaint to Defendant Mangan' s offi ce). 85. Native Americans are over-represented as victims of crime, and in the criminal justice system in Montana. Native Americans are arrested and incarcerated at a disproportionately higher rate than White Montanans. See 5002 (McCook), fl 79. 86. Given the disproportionate representation of Native Americans in Monkna's justice system, the penalty associated with BIPA along with its reporting requirement, will likely have a chilling effect that makes it even more likely that BIPA will deter ballot collection by Native Americans. 56