Ninth Circuit Narrows Qualifications for Being Qui Tam "Original Source"
Client Alert | 1 min read | 11.04.14
The Ninth Circuit, in Malhotra v. Steinberg (Oct. 29, 2014), held that, despite tipping off the government as to one kind of wrongdoing by the defendant, the FCA relators were not the "original source" of a different alleged act of wrongdoing perpetrated by the same defendant, a bankruptcy trustee. The relators independently discovered and alerted federal authorities to defendant trustee's scheme to sell property at a price lower than fair market value, but because that federal investigation led to the public disclosure of the defendant's receipt of kickbacks from those sales, the court held that the relators were not the original source of the kickback allegation which formed the basis of their qui tam action.
Insights
Client Alert | 7 min read | 11.02.26
DOL Finalizes PBM Fee Disclosure Requirements
On October 29, 2026, the U.S. Department of Labor’s (DOL) Employee Benefits Security Administration (EBSA) issued a 350-page final rule requiring providers of pharmacy benefit management services and their affiliated brokers and consultants to disclose fees and compensation received to fiduciaries of covered large, self-insured ERISA group health plans. According to DOL’s accompanying fact sheet, the disclosures will give employers more visibility into the payments PBMs may receive from various sources and help fiduciaries evaluate and monitor arrangements over time.
Client Alert | 4 min read | 10.30.26
Client Alert | 3 min read | 10.29.26
What University Licensors Should Learn From TexasLDPC v. Broadcom
