The Attorney Generals of Louisiana, Texas and Mississippi have asked the Fifth Circuit to overturn the Final Rules and a coalition of ten other Republican-led states (Alabama, Alaska, Georgia, Indiana, New Hampshire, Oklahoma, South Carolina, West Virginia, Wyoming and Virginia) have filed a petition asking the Eleventh Circuit to review the SEC's action in adopting the Final Rules. Energy industry suppliers Liberty Energy Inc. and Nomad Proppant Services LLC have also filed a lawsuit in the Fifth Circuit and both the U.S. Chamber of Commerce and the Sierra Club have hinted at possible litigation. Multiple lawsuits in multiple jurisdictions is likely to create some confusion and uncertainty as to the future of the Final Rules. However, public companies wishing to take a "wait and see" approach should note that, even if the courts rule against some or all of the mandates in the Final Rules, the SEC is still able to file enforcement actions against companies violating existing disclosure standards.