The United States Court of Appeals for the Fifth Circuit has issued a ruling that in all likelihood will relax the standard for language that must be used by whistle blowers filing cases under the federal False Claims Act. The opinion was reached in a health care fraud case in which the court considered the requirement of Federal Rule of Civil Procedure 9(b) that allegations of fraud in a complaint must be set forth with particularity. The decision is reported at United States v. Kanneganti, 2009 WL 930071 (5th Cir. 2009).

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