In July, GlaxoSmithKline ("GSK") became the latest pharmaceutical company to reach a global settlement with the Department of Justice to resolve both criminal and civil liability under the Food, Drug and Cosmetic Act ("FDCA") and under the False Claims Act ("FCA"). The resulting $3 billion settlement is the largest health care fraud resolution in history, surpassing the previous record set by the Pfizer settlement in 2009 for $2.3 billion.

The GSK case continues continues the trend of large civil settlements across multiple qui tam actions, criminal plea agreements, and increasingly aggressive settlement terms focused on wide-scale business practices and individual accountability.

The GSK settlement may not be the apex of this trend.

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