Defendant’s Reasonable Interpretation of Ambiguous Regulation Negates FCA Liability
Client Alert | 1 min read | 12.01.15
The D.C. Circuit overturned a jury verdict against MWI Corp., represented by C&M, in a long-running civil FCA suit in which the government asserted claims for approximately $225 million in trebled damages (plus additional civil penalties), alleging that false claims and statements were submitted to the Export-Import Bank in connection with eight loans to Nigeria for the purchase of MWI's water pumps. The court held that there was no evidence that the government "had officially warned MWI away from its otherwise facially reasonable interpretation of [an] undefined and ambiguous [regulatory] term" and ruled that, in such a situation, the FCA's knowledge/scienter element cannot be established.
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Client Alert | 7 min read | 12.19.25
In Bid to Ban “Woke AI,” White House Imposes Transparency Requirements on Contractors
In July 2025, President Trump signed Executive Order (EO) 14319, Preventing Woke AI in the Federal Government, to preclude the federal government from procuring artificial intelligence (AI) models that incorporate “ideological biases or social agendas,” including “diversity, equity, and inclusion.” The EO mandates that the federal government purchase only large language models (LLMs) developed according to two “Unbiased AI Principles” — that they be “truth-seeking” and show “ideological neutrality.” To implement these principles, the EO directed the Office of Management and Budget (OMB) to issue guidance.
Client Alert | 19 min read | 12.18.25
2025 GAO Bid Protest Annual Report: Where Have All the Protests Gone?
Client Alert | 7 min read | 12.17.25
Client Alert | 1 min read | 12.17.25
