D.C. Circuit Creates Split over the Reach of the First-to-File Bar
Client Alert | 1 min read | 04.18.14
In U.S. ex rel. Shea v. Verizon Co., the D.C. Circuit held that (1) two complaints may be "related" even if they involve different agencies or contracts, (2) the bar applies even when the same relator filed the earlier action, and (3) it continues to operate even after the earlier-filed action is resolved. The third holding (which drew a dissent) conflicts with dicta from two other circuits and the Fourth Circuit's 2013 opinion in U.S. ex rel. Carter v. Halliburton Co., petition for cert. filed (discussed here), holding that the first-to-file bar only applies while the earlier action is still pending.
Contacts
Insights
Client Alert | 10 min read | 12.24.25
Since the signing of Executive Order 14187 (“Protecting Children from Chemical & Surgical Mutilation”) in late January 2025, the Trump Administration has made its skeptical stance on gender-affirming care—especially regarding services provided to minors—clear.
Client Alert | 3 min read | 12.24.25
Keeping it Real: FTC Targets Fake Reviews in First Consumer Review Rule
Client Alert | 5 min read | 12.23.25
An ITAR-ly Critical Reminder of Cybersecurity Requirements: DOJ Settles with Swiss Automation, Inc.
Client Alert | 2 min read | 12.23.25
Record-Setting False Claims Act Settlement Highlights DOJ Commitment to Customs Enforcement

