With the rise in cases surviving motions to dismiss, educational institutions are reasonably concerned about the costs of and disruption caused by discovery. One possible solution is conducting phased discovery--enabling discovery on discrete, case-dispostive issues in an early phase to avoid unnecessary and costly discovery. However, courts have yet to clearly outline the boundaries for where phased discovery is appropriate. In United States ex rel. Lee v. Corinthian Colleges, et al., Case No. 07-cv-1984-PSG (MANx) (C.D. Cal.), the court allowed discovery to proceed in phases, with the first phase focused on depositions of the relators and written discovery relating to the Court's jurisdiction under the FCA. In contrast, in United States v. Education Management Corp., 2:07-cv-00461-TFM (W.D. Pa), the court denied EDMC's request to have an initial phase of discovery involving salary data and the presentation of experts demonstrating why that data should be dispositive in the case, instead granting conventional, unlimited discovery. Thus, while jurisdictional issues appear to be appropriate for phased discovery, it is unclear how far (or if) the possibility of phased discovery extends beyond those issues.