Disclosure to Public Officials Is Not "Public": Relator to Have Yet Another Day in Court
Client Alert | 1 min read | 02.05.15
The "long and winding road" of U.S. ex rel. Wilson v. Graham County, which has twice taken it to the Supreme Court and back, will continue on remand after the Fourth Circuit reversed the district court's dismissal for want of jurisdiction. Siding with five other circuits in a rebuke of the Seventh Circuit's holding in U.S. v. Bank of Farmington that disclosure to a "competent" public official authorized to act on the information was sufficient to trigger the FCA's public disclosure bar, the Fourth Circuit ruled instead that information shared within the government, even between federal, state, and local agencies, has not reached the public domain, notwithstanding its availability through a public records request.
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Client Alert | 14 min read | 03.13.26
AI for Government: 7 Days for Contractor Comments on GSA Proposed Contract Clause for AI Systems
On March 6, 2026, the General Services Administration (GSA) issued a significant proposed contract clause, GSAR 552.239-7001, Basic Safeguarding of Artificial Intelligence Systems (“Clause”), for inclusion in GSA Schedule solicitations and contracts for AI capabilities. The proposed clause would impose substantial new requirements related to AI sources, intellectual property rights, data use, change management, and performance standards. The Clause would also take precedence over any other contract terms (including commercial licensing terms) related to AI, including a Seller’s terms of sale and service to which the Government had previously agreed. GSA requests comments by March 20, 2026.
Client Alert | 3 min read | 03.12.26
DOJ Releases First-Ever Department-Wide Corporate Enforcement and Voluntary Self-Disclosure Policy
Client Alert | 3 min read | 03.12.26
