Court Applies Totten Reasoning To Subcontractor Liability Under FCA
Client Alert | 1 min read | 03.23.05
Applying the reasoning of the D.C. Circuit in U.S. ex rel. Totten v. Bombardier Corp., 380 F.3d 488 (D.C. Cir. 2004), regarding lack of False Claims Act (FCA) liability for claims made by contractors of federal grantees when those claims are not presented to the Government for payment [see Crowell & Moring Bullet Points 9/16/2004 and 12/16/04), the Southern District of Ohio in U.S. ex rel. Sanders v. Allison Engine Co. (Mar. 11, 2005) dismissed a qui tam case for failure to present evidence that the defendant subcontractor's claims had been presented to the government for payment. In so doing, the court distinguished longstanding Supreme Court precedent imposing subcontractor liability when the prime passes the sub's false claim up to the government.
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Client Alert | 4 min read | 11.18.25
DOJ Announces Major Enforcement Actions Targeting North Korean Remote IT Worker Schemes
On November 14, 2025, the U.S. Department of Justice (DOJ) announced a sweeping series of enforcement actions, including four guilty pleas and more than $15 million in civil forfeitures against the Democratic People’s Republic of Korea (DPRK or North Korea) for remote information technology (IT) worker schemes. These actions underscore the federal government’s escalating focus on the exposure of U.S. companies to North Korean IT worker infiltration, following a series of U.S. Government action against the DPRK.
Client Alert | 2 min read | 11.14.25
Client Alert | 6 min read | 11.14.25
Microplastics Update: Regulatory and Litigation Developments in 2025
