Cafasso

In this False Claims Act (“FCA”) appeal, relator Mary Cafasso challenges orders of the district court dismissing her qui tarn complaint, rejecting her proposed amended pleading, granting summary judgment on remaining claims, and awarding attorneys’ fees. We have jurisdiction pursuant to 28 U.S.C. § 1291 , and we affirm.

I

Cafasso alleges that her former employer General Dynamics C4 Systems (“GDC4S”), a technology company that services the military, defrauded the government by withholding disclosure of new inventions which, GDC4S had agreed by contract, the government had rights to use and license. Cafasso discovered the alleged fraud, according to her complaint, and made repeated inquiries and requests for internal audits. She claims that as a result of her activities in that regard, GDC4S retaliated against her by eliminating her department and position. GDC4S denies those allegations.

After learning that her job would be terminated but before leaving GDC4S, Cafasso copied almost eleven gigabytes of data from company computers in anticipation of bringing a qui tam action. Within days of her departure, GDC4S realized that she had taken thousands of its internal…