This is a significant decision, given how often non-U.S. clients entrust U.S. law firms with their documents.

A motion to dismiss in United States et al. v. Novartis Pharmaceuticals Corp., 11 Civ. 0071, fully briefed as of December 23, 2013, could have significant consequences for the application of Federal Rule of Civil Procedure 9(b) to cases brought under the False Claims Act in the Southern District of New York.