OPINION
CHIN, Circuit Judge.
Qui tam relator Cleuza Colucci ("Colucci") brings this action on behalf of the United States against Beth Israel Medical Center ("BIMC"), Mort Hyman, Tom Hayes, and Robert Naldi under the False Claims Act (the "FCA"). Colucci seeks per-claim penalties and treble damages exceeding $1.5 billion, alleging that defendants submitted false claims to Medicare related to BIMC's Graduate Medical Education program. Specifically...
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