Can a plaintiff bring multiple identical actions against the same defendant under the False Claims Act?

The court reached the same conclusion in Simonian v. Quigley Corp., 2010 WL 2837180 (N.D. Ill. July 19, 2010). In that case, plaintiff filed an action against the same defendant, asserting identical claims as those filed by another plaintiff hours earlier in New York. In dismissing the second-filed action, the court noted 292 "contemplates only a single action brought by a private individual on behalf of the United States." Id. at *2. "Just as the United States could not bring multiple identical actions under the false marking statute, multiple private plaintiff's cannot do so on the government's behalf." Id. These cases are consistent with the general line of cases under the False Claims Act (prior to its amendment to add an explicit first-to-file bar), that the statute contemplates only a single action brought by a private individual on behalf of the United States.