The Times They Are A’Changing – Or Are They? DOJ Announces It Will Move To Dismiss Qui Tam Complaints That Lack Merit
Client Alert | 1 min read | 11.13.17
After months of signaling that a change to the Department of Justice’s qui tam practices was imminent, Michael Granston, Director of the Civil Fraud Section, announced the change during a presentation at the Health Care Compliance Association’s Health Care Enforcement Compliance Institute on October 30. The Department of Justice will now move to dismiss a qui tam complaint when it concludes that it lacks merit. Although announced as a means of conserving judicial and litigant resources, we also wonder if the apparent change is spurred by a concern over the creation of bad law under Escobar’s materiality standard is a driving force behind this decision. Given that DOJ rarely exercises its statutory authority to move to dismiss a qui tam complaint, it should not be difficult to ascertain whether DOJ’s announcement is, in fact, a sign of a real shift in its enforcement tactics.
Insights
Client Alert | 3 min read | 12.13.24
New FTC Telemarketing Sales Rule Amendments
The Federal Trade Commission (“FTC”) recently announced that it approved final amendments to its Telemarketing Sales Rule (“TSR”), broadening the rule’s coverage to inbound calls for technical support (“Tech Support”) services. For example, if a Tech Support company presents a pop-up alert (such as one that claims consumers’ computers or other devices are infected with malware or other problems) or uses a direct mail solicitation to induce consumers to call about Tech Support services, that conduct would violate the amended TSR.
Client Alert | 3 min read | 12.10.24
Fast Lane to the Future: FCC Greenlights Smarter, Safer Cars
Client Alert | 6 min read | 12.09.24
Eleven States Sue Asset Managers Alleging ESG Conspiracy to Restrict Coal Production
Client Alert | 3 min read | 12.09.24
New York Department of Labor Issues Guidance Regarding Paid Prenatal Leave, Taking Effect January 1