California Appellate Tracker

State ex rel. Edelweiss Fund, LLC v. JPMorgan Chase & Co., 90 Cal. App. 5th 1119, 307 Cal. Rptr. 3d 750 (2023)

July 23, 2023

Under California’s False Claims Act, there is a public disclosure bar to suit if the information on which the suit is based was publicly disclosed in a criminal, civil, or administrative hearing, in a report, hearing, audit or investigation by the Legislature, or in news media. (Gov. Code 12652(d)(3)(A).) This decision holds that interest rates on government bonds automatically reported on the Electronic Municipal Market Access website are not disclosed in any of these ways. The website is not a hearing or any act by the Legislature. It also is not a news medium, but simply a repository of information that is required to be disclosed.

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California Appellate Tracker

State ex rel. Edelweiss Fund, LLC v. JPMorgan Chase & Co., 90 Cal. App. 5th 1119, 307 Cal. Rptr. 3d 750 (2023)

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