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What DOJ’s 2022 Recovery Stats Reveal About FCA Enforcement Trends

Client Alert | 1 min read | 02.13.23

On February 7, 2023, the Department of Justice issued the False Claims Act (FCA) recovery statistics for fiscal year 2022. While the $2.2 billion recovered by the Department and qui tam relators was down from the prior year, 2022 saw a record number of new FCA matters initiated. Underscoring the flurry of FCA activity, there were 351 settlements and judgments in 2022, the second-highest number recorded in a fiscal year.

In an Expert Analysis article published in Law360, C&M attorneys analyze what the 2022 fiscal year recovery statistics reveal about potential FCA enforcement trends in the year ahead.

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Client Alert | 3 min read | 07.18.25

Eighth Circuit Cancels Click-to-Cancel

On July 8, 2025, the Eighth Circuit vacated the Federal Trade Commission’s (“FTC”) Negative Option Rule, also known as the Click-to-Cancel Rule, on procedural grounds. The Click-to-Cancel Rule, which provided a streamlined path for consumers to cancel subscription services in a few clicks of a mouse, was scheduled to take effect on July 14, 2025, but the Court found that the FTC had failed to follow mandatory procedural requirements....