In January 2018, two days after the Oregon Secretary of State implemented new rules changing how signatures could be gathered for statewide initiative petitions, Steve Berman filed a lawsuit on behalf of an Oregon voter alleging that the new rules were illegal and that the Secretary of State lacked the authority to implement the rules. The voter also moved for a temporary restraining order, to prevent the rule changes from going into effect. The rule changes would have allowed initiative supporters to gather signatures using a non-final ballot title (a neutral summary of the initiative), while the ballot title was being reviewed by the Oregon Supreme Court. On the eve of the TRO hearing, the Secretary of State rescinded the rules. The Secretary of State successfully withdrew those rules.