Sixth Circuit Recognizes Exception to Heightened Standard for Pleading False Claim
Client Alert | less than 1 min read | 10.12.16
In U.S. ex rel. Prather v. Brookdale Senior Living Communities Inc. (Sept. 30, 2016), the Sixth Circuit held that a relator pled the “presentment” element even though the relator did not allege information regarding the submission of a specific request for payment. The court reasoned that, in the majority of cases, plaintiffs would need to plead representative false claims but that a relator could survive a motion to dismiss by pleading specific facts based on personal, billing-related knowledge that support a strong inference that specific false claims were submitted for payment.
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Client Alert | 4 min read | 04.08.26
Cosmetics Under the Microscope: FDA’s Expanding Regulatory Reach Under MoCRA
The Modernization of Cosmetics Regulation Act of 2022 (MoCRA) marked the most significant expansion of FDA’s authority over cosmetics in 80 years — and the agency is putting that authority to work. From the launch of a new adverse event reporting tool to forthcoming rules on fragrance allergens and good manufacturing practices (GMP), FDA is reshaping the regulatory landscape for manufacturers, packers, and distributors of cosmetic and personal care products.
Client Alert | 11 min read | 04.08.26
Client Alert | 3 min read | 04.07.26
Answering the Top Seven Questions About Pending Section 301 Deadlines


