On 23 March 2020 the U.S. Court of Appeals for the Seventh Circuit issued a decision on NoerrPennington's sham exception, increasing a circuit split on the proper analysis of "serial petitioning" claims. U.S. Futures Exchange, LLC v. Board of Trade of the City of Chicago, Inc., No. 18-3558 (7th Cir. 23 March 2020). The Seventh Circuit held that each petition in the alleged "series" must be objectively baseless for the sham exception to apply – diverging from a number of circuits that have found that a showing of objective baselessness is required only in single petition claims, not in serial petitioning sham claims.