1. Whether the D.C. Circuit erred by requiring plaintiffs to anticipate and negate in their complaint a False Claims Act affirmative defense, in direct conflict with Cunningham v. Cornell University, 145 S. Ct. 1020 (2025), and basic principles of civil procedure.

2. Whether a False Claims Act plaintiff's independent knowledge that prompts a multi-year fraud investigation "materially adds" to what is publicly disclosed under 31 U.S.C. § 3730(e)(4)(B), or whether it must be so substantial it is likely to prompt the government to intervene and prosecute the fraud, as the D.C. Circuit held, deepening a conflict among the federal courts of appeals.

Whether the D.C. Circuit erred by requiring plaintiffs to anticipate and negate in their complaint a False Claims Act affirmative defense, in direct conflict with Cunningham v. Cornell University, 145 S. Ct. 1020 (2025), and basic principles of civil procedure