Home Compliance Relying on Escobar, Ninth Circuit Tosses Implied Certification Case ComplianceExpert OpinionNews Relying on Escobar, Ninth Circuit Tosses Implied Certification Case January 17, 2017 9 Share FacebookLinkedinTwitter You must be a Paid or Free Trial Member to Access this Content. Paid members, please login to view your news subscription(s). RELATED ARTICLESMORE FROM AUTHOR Claims Contractor May Have Pleaded Guilty to Fraud, But that Didn’t Mean the Government Could Recoup Performance-Based Fees Compliance Second Circuit Reinforces Anti-Kickback Statute’s Demanding Willfulness Standard Compliance Husch Blackwell Launches New FCA-Themed Podcast