1. Is a qui tam relator barred by the "public disclosure" of its own prior complaint? No other circuit court has so held.

2. Does the public-disclosure bar apply to the unsealing of a first-filed complaint after the relator filed its first complaint, but before it re-filed its second complaint? No other circuit court has so held.

3. Was the Second Circuit correct in interpreting the False Claims Act in a way that bars any relator from being an "original source"? Other circuit courts have expressly interpreted the act to hold the opposite.

Is a qui tam relator barred by the 'public disclosure' of its own prior complaint, and does the public-disclosure bar apply to the unsealing of a first-filed complaint before re-filing a second complaint?