Page:Wood v. Raffensperger (20-14418) (2020) Decision.pdf/15

 effect of those rules harmed the electorate collectively. That alleged harm is not a particularized injury.

Wood suggested in his amended complaint that his status as a donor contributed to standing and aligned his interests with those of the Georgia Republican Party. But he forfeited this argument when he failed to raise it in his opening brief. ''Access Now, Inc. v. Sw. Airlines Co., 385 F.3d 1324, 1335 (11th Cir. 2004); see also Nat’l All. for the Mentally Ill v. Bd. of Cnty. Comm’rs'', 376 F.3d 1292, 1296 (11th Cir. 2004) (ruling standing claims forfeited for failure to comply with the Federal Rules of Appellate Procedure). And the donor argument fails on its own terms. True, a donor can establish standing based on injuries that flow from his status as a donor. See, e.g., ''Wilding v. DNC Servs. Corp.'', 941 F.3d 1116, 1125 (11th Cir. 2019). But donors, like voters, “have no judicially enforceable interest in the outcome of an election.” Jacobson, 974 F.3d at 1246. Nor does a donation give the donor a legally cognizable interest in the proper administration of elections. Any injury to Wood based on election irregularities must flow from his status as a voter, unrelated to his donations. And that fact returns him to the stumbling block of particularization.

“[T]he ‘injury in fact’ test requires… that the party seeking review be himself among the injured.” Lujan, 504 U.S. at 563 (internal quotation marks omitted). Wood’s allegations suggest that various nonparties might have a