Thanks

The argument that will be made - and has already been made by Gibson Dunn on behalf of Ryan, LLC - is that the Noncompete Rule violates the Constitution in a number of ways (unconstitutional delegation of legislative power in contravention of Article I; FTC Act's removal protection for Commissioners violates the Vesting Clause of Article II).

For what it's worth, I think that analysis by courts will likely involve the FTC Act, the APA, application of the "major questions" doctrine, and the Constitution. Glad people far smarter than me will be deciding this.