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

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 subst antial 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.