and do not implicate the First Amendment, rational basis scrutiny is appropriate. See District of Columbia v. Heller, 554 U.S. 570, 628 n. 27, 128 S.Ct. 2783, 2817 n. 27, 171 L.Ed.2d 637 (2008). Steen justifies the Non-Resident provisions as an important safeguard in preventing fraud. He contends that if out-of-state residents were to act as VDRs, they could be less easily deterred from breaking the law because they could easily remove themselves from the juris diction of state investigators and prosecutors. Steen similarly justifies the County Provision as a means to increase accountability of VDRs by facilitating revocation of their appointments in cases of negligence, fraud or violation of registrants’ privacy. These are rational bases for the provisions. Cf. Jaeger, 241 F.3d at 616 (<HOLDING>). Even assuming arguendo that the NonResident
holding state law fraud and deceit claims to be preempted holding that a plaintiff has a duty to plead the date of discovery of fraud where the alleged fraud apparently occurred at a remote time holding that the state has a compelling interest in preventing fraud and that the residency requirement allows north dakotas secretary of state to protect the petition process from fraud and abuse by ensuring that circulators answer to the secretarys subpoena power holding that a plaintiff cannot avoid the securities fraud exception by pleading mail fraud or wire fraud if the conduct giving rise to those offenses also amounts to securities fraud holding that under the pre1986 jurisdictional limitation a claim by the state which discovered the fraud investigated the fraud disclosed the fraud to the federal government and which was the original source of the information was jurisdictionally barred