Whether the number of FCA civil penalties is based upon the number of overpayments received by a Section 8 landlord or whether they are based upon the number of times the landlord presents a fraudulent claim or statement to the government;

2. Whether FCA treble damages are based upon the total amount paid out by the government or whether they are based upon the sum of the overpayments alone; and

3. Whether due process is violated when a court imposes FCA civil penalties and treble damages that come to nearly 27 times the total amount of overpayments.

Whether the number of FCA civil penalties is based upon the number of overpayments received by a Section 8 landlord or whether they are based upon the number of times the landlord presents a fraudulent claim or statement to the government