briefs related to additional authority upon which defendant relied during oral argument. With briefing fully completed, the court is prepared to rule. III. LEGAL STANDARDS A. RCFC 12(b)(1) Motion to Dismiss The burden of establishing the court’s subject matter jurisdiction resides with the party seeking to invoke it. McNutt v. Gen. Motors Acceptance Corp. of Ind., 298 U.S. 178, 189, 56 S.Ct. 780, 80 L.Ed. 1135 (1936); see also Reynolds v. Army & Air Force Exch. Serv., 846 F.2d 746, 748 (Fed.Cir.1988) (stating that the plaintiff bears the burden of establishing jurisdiction by a preponderance of the evidence). The court “consider[s] the facts alleged in the complaint to be true and correct.” Reynolds, 846 F.2d at 747; see also Henke v. United States, 60 F.3d 795, 797 (Fed.Cir.1995) (<HOLDING>); cf. Betz v. United States, 40 Fed.Cl. 286,
recognizing the courts obligation to assume all factual allegations to be true and to draw all reasonable inferences in plaintiffs favor holding that for purposes of a class certification motion the court must accept as true all factual allegations in the complaint and may draw reasonable inferences therefrom holding court obligated to draw all reasonable inferences in plaintiffs favor holding courts are obligated to draw all reasonable inferences in plaintiffs favor holding that courts are obligated to draw all reasonable inferences in plaintiffs favor