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increasingly added to FCA complaints filed in federal court or filed alone in state courts,and there has been a fast developing capability on the part of state fraud enforcementauthorities to pursue these cases and share in the recoveries being driven bywhistleblower reporting.1. FCA Whistleblower Case Recoveries and Related IssuesIn November 2014, the DOJ announced a record setting $5.69 billion in recoveriesunder the FCA for fiscal year 2014, including nearly $3 billion in recoveries related toactions filed by whistleblowers under the FCA. 7 The government paid $435 million towhistleblowers who filed qui tam complaints under the FCA in FY 2014, and reported713 newly filed lawsuits under the qui tam provisions of the statute. As stated by theDOJ, “[t]he growing number of qui tam lawsuits filed since 2009 has led to increasedrecoveries, which exceeded $2 billion for the first time in fiscal year 2010, and hasapproached or exceeded $3 billion ever since.” 8It is apparent to practitioners handling FCA cases that the DOJ has come toincreasingly rely on whistleblowers to assist in the detection and reporting of fraud.While the numbers of FCA cases accepted for intervention by the government have notgrown substantially, whistleblowers are viewed by the government as important sourcesof reported fraud in connection with government contract and other regulated activityand are expressly encouraged. In response to the typical lament of FCA targets thatfalse claims allegations are the product of “disgruntled former employees,” the7 Press Release, U.S. Department of Justice, Justice Department Recovers Nearly $6 Billion from FalseClaims Act Cases in Fiscal Year 2014 (Nov. 20, 2014), http://www.justice.gov/opa/pr/justicedepartment-recovers-nearly-6-billion-false-claims-act-cases-fiscal-year-2014.8 Id.4