Fraud Under The FCA

. that might result in financial loss to the Government.” United States v. Neifert-White Co., 390 U.S. 228, 232 (1968). Accordingly, “[f]alse claims under the FCA take a variety of forms.” United States v. Sci. Applications Int’l Corp., 626 F.3d 1257, 1266 (D.C. Cir. 2010). These include: (1) presentment claims; (2) fraudulent inducement claims; and (3) false certification (express or implied) claims. See id. (endorsing implied false certification theory as basis for FCA claims in D.C. Circuit); U.S. ex rel. Bettis v. Odebrecht Contractors of Cal., Inc., 393 F.3d 1321, 1326 (D.C. Cir. 2005) (recognizing that claims based upon fraudulent inducement are actionable under the FCA). To state a claim for a false claim under the FCA, a plaintiff must show that “(1) the defendant submitted a claim to the government, (2) the claim was false, and (3) defendant knew the claim was false.”

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