In Hillanbrand v. Pennsylvania Board of Probation and Parole, 96 Pa. Commw. 484, 508 A.2d 375 (Pa. Cmwlth. 1986), the Court dismissed an untimely appeal as frivolous because this court lacks jurisdiction over untimely appeals. Because section 6602(e)(2) of the PLRA does not limit the bases for determining whether litigation is frivolous and because litigation may be dismissed as frivolous for lack of jurisdiction, a dismissal based on jurisdiction counts as a "strike" under section 6602(f)(1) of the PLRA.