id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
cblr-2909	Nicolaou, John T.	Whistle While You Work: How the False Claims Act Amendments Protect Internal Whistleblowers	2012	55	.pdf	application/pdf	20615	843	49	Significantly, the disjunction of the two actions allows private plaintiffs to avoid the heightened pleading standards of Federal Rule of Civil Procedure 9(b), which applies to FCA fraud actions. Under this standard, protected actions need not have resulted in any party securing a judgment or settlement against the defendant for FCA fraud or even in any party filing an actual FCA fraud claim, because the statute's to be filed clause links protection to events as they were understood at the ' False Claims Act, 31 U.S.C. § 3730(h)	cache/cblr-2909.pdf	txt/cblr-2909.txt