One of the more prominent False Claims Act cases to reach the U.S. Supreme Court in recent memory was the Escobar case, which among other things raised the requirements for the materiality of a qui tam relator's allegations. However, the lower courts have exhibited a tendency to interpret the Supreme Court's decision in Escobar in varying ways, according to a new briefing by the law firm of Gibson Dunn, suggesting that those in the life sciences will have to watch carefully as this and other FCA matters work their way through the courts.