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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 | 5 min read | 04.09.26

U.S. State Privacy Enforcement: Key Priorities and Practical Guidance From State Regulators

At the International Association of Privacy Professionals’ (IAPP) annual conference March 30-31, 2026, enforcement officials from California, Connecticut, Indiana, and Delaware shared their current and upcoming enforcement priorities under U.S. state consumer privacy laws. This alert summarizes the key themes from the panel and offers practical guidance for companies navigating the evolving enforcement landscape....