The brief calls out Acheson’s attempts to argue the merits of Ms. Laufer’s case as a distraction to the straightforward standing inquiry at hand. Standing is a threshold issue that requires plaintiff’s allegations be taken as true. This low bar is cleared by the mere allegation of a concrete injury. Arguments about the merit of Ms. Laufer’s case including whether she experienced the “right type of discrimination” that warrants ADA protection and the degree of emotional harm she suffered are inappropriate to the threshold matter of standing and subject to review in future motions. In summary, Ms. Laufer alleges that she personally experienced discrimination, a harm in itself sufficient for standing, so Ms. Laufer has standing.