3. Even before Twombly and Iqbal, some courts imposed heightened pleading standards in civil rights and complex cases. See p. 569, supra. Does the new standard raise the bar by requiring the pleading of particularized facts? See Clermont & Yeazell, Inventing Tests, Destabilizing Systems, 95 Iowa L. Rev. 821 (2010). Does such a requirement make it difficult even for plaintiffs with meritorious claims to survive a motion to dismiss? Keep in mind that generally the court will resolve the motion to dismiss prior to any exchange of information