Law360, New York (July 16, 2012, 1:05 PM ET) -- Recently, the United States District Court for the District of Massachusetts found that a relator’s complaint was barred by the False Claims Act’s first-to-file requirement and dismissed the relator’s complaint. United States ex rel. Heineman-Guta v. Guidant Corp., et al. (No. 09-CV-11927-RGS). In holding that a previously filed complaint does not need to satisfy Federal Rule of Civil Procedure 9(b) in order to bar a later-filed FCA claim, the court intensified a developing divide among courts about the breadth of the FCA’s first-to-file rule.