The three-way split among federal courts traces directly to the absence of a Judicial Conference rule. What exists instead is momentum from a single event — Mata v. Avianca — scaled unevenly across districts. The Eastern District of Virginia's evolving guidance illustrates the pattern: individual judges issuing standing orders that reflect personal thresholds rather than coordinated policy. The result is a compliance landscape where the controlling standard depends entirely on which judge drew the case. Attorneys who file across districts are not navigating a graduated risk — they are navigating…