Article
ND Ill. Dismisses FCA Cybersecurity Claim Premised On Regulatory Noncompliance, Finding Lack Of Materiality
A federal court dismissed an FCA case against Archer Daniels Midland alleging false cybersecurity representations, establishing that regulatory noncompliance alone is insufficient without proof the government relied on those representations in payment decisions. The ruling clarifies the high materiality threshold for cybersecurity-based False Claims Act litigation and underscores what relators must demonstrate when alleging fraud through implied certification theories.
Goodwin Procter LLP
