Deepening a circuit split, the Seventh Circuit has joined the Fifth Circuit in rejecting the implied false certification theory of liability under the FCA.  United States v. Sanford-Brown, Ltd., No. 14-2506 (7th Cir., June 8, 2015).  The Fourth, Ninth, Tenth and District of Columbia Circuits have allowed implied false certification claims. The implied false certification theory holds that when an entity enters into an agreement...