Davis-Bacon Violation Leads to FCA Liability
Client Alert | 1 min read | 10.16.12
On October 1, the Sixth Circuit in United States ex rel. Wall v. Circle C Constr., LLC, affirmed a decision imposing FCA liability when a prime had submitted inaccurate or false payroll certifications that did not properly describe work done by its subcontractors and that also contained hourly wages for subcontractor employees that did not meet federal guidelines for prevailing wages under the Davis-Bacon Act. This opinion serves as an important reminder to primes and subcontractors that failure to comply with minimum wage rate requirements may have significant adverse consequences and also suggests that companies that learn of such violations must carefully consider whether mandatory disclosure pursuant to FAR Subpart 9.4 or 52.203-13 is required.
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Client Alert | 3 min read | 06.30.25
The New EU “Pharma Package”: Preparing for the Trilogues
On June 4, 2025, after nearly two years of intense debate and negotiation between the 27 EU Member States, the Council of the European Union adopted its position on the proposed overhaul of the EU general pharmaceutical legislative framework known as the new Pharma Package.
Client Alert | 3 min read | 06.26.25
FDA Targets Gene Editing Clinical Trials in China and other “Hostile Countries”
Client Alert | 3 min read | 06.26.25
Client Alert | 4 min read | 06.26.25
Ninth Circuit Affirms that CIPA Only Applies to Third-Party Eavesdropping
