The Supreme Court recently held that information received in writing through an FOIA request constitutes a "public disclosure" under the False Claims Act, which could preclude recovery for a whistleblower who received written responses to FOIA requests, in the absence of that person being an "original source" of the information. This provision of the Act - the "public-disclosure bar" - has been used very aggressively in the last 10 years by defendants to dismiss qui tam complaints filed by whistleblowers. But proponents of the Act continue to press for Congress to weaken the provision through amendment. In healthcare-related cases, they have succeeded with section 10104(j)(2) of the Patient Protection and Affordable Care Act, which gives standing to the DOJ to oppose a defendant's dismissal of a False Claims Act complaint based on the public-disclosure bar.