UPDATE: A U.S. District Court Judge in Beaumont, Texas, has issued a nationwide preliminary injunction. Read the e-lert here.
As courts across the nation search for equilibrium after the Escobar decision, potential FCA defendants are watching closely to see the measure of their potential FCA liability for failure to observe contractual, regulatory, or legal obligations. On October 25, 2016, these possibilities will grow exponentially for many government contractors when the so-called Fair Pay and Safe Workplaces final rule (“the Rule”) goes into effect. See 81 Fed. Reg. 58562 (August, 25, 2016).