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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.

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Client Alert | 3 min read | 05.14.26

CISA’s “CI Fortify” Initiative Signals New Expectations for Critical Infrastructure Resilience: What Operators and Vendors Need to Know

On May 5, 2026, CISA announced CI Fortify — an initiative directing critical infrastructure owners and operators to prepare for geopolitical conflict in which OT networks are actively targeted while communications infrastructure is simultaneously degraded....