Absolutely, it's obviously a desperation Hail Mary play, but not before Comey spends several thousand dollars on lawyers, after spending a whole lot to defend himself the last time.

Perhaps there is a family strategy at play. His daughter was fired as a Federal prosecutor, after working on high profile cases like Epstein. She is now sueing the DoJ, and will probably win, so maybe she can use some of that government money to cover her Dad's legal bills.

He should also sue for malicious prosecution.

Yes, but it is intended as harassment, not "justice".

He still needs a lawyer, he can't just ignore it.

If nothing else than for the fact that Trump and friends made public statements condemning him. Can't really have an impartial jury after that