On May 20, 2009 the Fraud Enforcement and Recovery Act of 2009 (“FERA”) was signed into law by President Obama. FERA expands the reach of the False Claims Act (“FCA”). The Act overrules the Allison Engine and Bombardier precedent. FERA “clarifies” that the FCA covers claims for money or property irrespective of whether the claim was “presented” to a federal employee or official, whether the federal government actually had custody of the money or property or made payments, whether the submitter specifically intended to defraud the federal government, and whether the claim was submitted to the government directly or [...]