United States ex rel. Noah Nathan v. Takeda Pharmaceuticals, Inc. North America, Inc.

Whether Rule 9(b) of the Federal Rules of Civil Procedure requires that a complaint under the False Claims Act "allege with particularity that specific false claims actually were presented to the government for payment," as required by the Fourth, Sixth, Eighth, and Eleventh Circuits, or whether it is instead sufficient to allege the "particular details of" the "scheme to submit false claims" together with sufficient indicia that false claims were submitted, as held by the First, Fifth, Seventh, and Ninth Circuits.