Berg further indicates that under 8 USC 1481(a)(1)  when Obama became Indonesian, he gave up his citizenship, and could only re-obtain it by renouncing the Indonesian citizenship when he turned 18, and by taking proper measures to regain his U.S. citizenship.  He says pursuant to 1481(b), the burden is upon Obama to prove that he is a citizen, something he has not and cannot do.  In support, Berg indicates that Obama was still traveling on an Indonesian passport in 1981 when he was 20 years old, which lends the strong inference that he had after 18 again affirmed his allegiance to Indonesia, thus preventing him from having U.S. Citizenship.  Taking  an  oath  or  making  an affirmation  or  other  formal  declaration  of  allegiance  to  a  foreign  state...after  having attained the age of  eighteen years provides loss of nationality by native born citizens, 8 USC §1481(a)(2).

Berg then claims under 5 USC 552 (FOIA) Freedom of Information Act, that anyone denied information there under has standing to sue regardless of his reasons.  Again citing Atkins, he discusses how a voter suffers a particularized injury if he is deprived of useful information at the time he votes.

Berg also cites 28 USC 1343 under Civil Rights an Elective Franchise, stating Plaintiff  has  the  right  to  secure  equitable  relief under 28  U.S.C.  1343(a)(3)  and
(4).  In Baker v. Carr, 369 U.S. 186 (1962), federal jurisdiction arose under this section and Plaintiff had standing because his individual right to vote was affected.  Like many other United States citizens, Plaintiff  lost the opportunity  to vote in the general election for a qualified  Democratic  candidate,  because  Obama  withheld  information  critical  to determining his ineligibility for residency, knowing he was not a "natural born" citizen much  less  a  citizen  at  all  and  knowing  he  was  ineligible  to  serve  as  President  of  the United  States.    Based  on Obama's  fraud,  people  supported  him  instead  of  an  eligible candidate.

Berg isn't finished yet, citing 28 USC 1331 and a case for the proposition that if there is a question of Federal law or the Constitution, the Federal Court has jurisdiction, even if the issue of law has already been decided.  He says this is clearly a constitutional issue for which there is no specific constitution redress, i.e. the Constitution is silent on who has the authority to resolve disputes as to presidential candidate eligibility and or determination of compliance with the law on that issue.  There is in fact no statute, law, or case that discusses how a voter can demand proof of presidential eligibility when the DNC and FEC refuse to do their job.  This, he claims is the first time in history this "Federal Question" has arisen, and the Constitution generally guarantees a remedy.

Berg then goes into details of his causes of action and why they are viable causes of action. 
Obama's motion is quite short with only a few cases and statutes.  Berg makes a long and detailed argument for standing, and is quite persuasive.  However, Obama's attorneys have the right to file a Reply brief to rebut Berg's arguments,

Berg essentially turns it around and says the the Hollander case helps him not hurts him.  It should be noted that Berg amended his complaint and creatively added some cause of action in personal injury and fraud.

Berg then moves on to 5 USC 702 (U.S.Codes) saying that he tried to obtain the documents from the DNC and FEC, he and others asked them to investigate and were ignored.  He claims under this section that he can thus add the U.S. or federal authority as a party because they failed to take any action or investigate Obama, let alone the $400 million he has obtained through campaign contributions.  He then bootstraps that to 2 USC 437(c ) and (d) essentially indicating that since those statutes provide the authority for the DNC and FEC to require Obama to provide the documents and answer the questions, and since they have not, they have neglected their duties and can be civilly sued under the 702 section.  If Obama was not legally able to prove his status under 437(g), then he has perpetrated a fraud on the American people and the government, by collecting the said $400 million.  He then says "When  Congress  confers  standing  on  litigants,  the  generalized  grievance constriction does not apply.   Congress confers standing on any individual who has been aggrieved by  the  denial  of  information  required  to  be  furnished  pursuant  to Statute.    It matters not that most people are or will be entitled and suffer a "generalized grievance",  the statutory entitlement is sufficient.  FEC v. Akins, 524 U.S. 11 (1998)."   

Obama's motion to dismiss is based upon the idea that any voter does not have proper standing because his injury is not certain as it is not individual to him.  Obama's attorneys cite some cases including one where McCain was sued by a voter and it is claimed that the lawsuit was dismissed because of the lack of standing.  In their argument, the Obama attorneys argument sounds pretty compelling, especially when they make it sound like the Hollander v. McCain case is right on point, is precedent.