tam complaints, Relator Mayes and Relators Lutz and Webster have filed amended complaints. 2 . In briefing related to the multiple pending motions to dismiss, some Defendants argue that the 2010 amendment that made it clear that a claim resulting from an AKS violation was a false claim operated only in a prospective nature, (See, e.g,, Dkt. No. 146-1 at 17). However, this Court finds that the weight of authority supports the conclusion that the 2010 amendment adding 42 U.S.C. 1320a-7b(g) was merely a clarification of the law; claims tainted by AKS violations constitute false claims for the purposes of the FCA regardless of whether the violation occurred before or after the 2010 amendment. See, e.g., U.S. ex rel. Wilkins v. United Health Grp., Inc., 659 F.3d 295, 312 n.19 (3d Cir. 2011) (<HOLDING>); U.S. ex rel. Westmoreland v. Amgen, Inc., 812
holding that a legislative amendment that appeared to approve the analysis of a recent indiana supreme court case was a clarification rather than an amendment holding the sixth amendment applicable to the states through the fourteenth amendment holding that the fourteenth amendment incorporated the sixth amendment right to counsel holding that federal rule of civil procedure 15c2 giving court discretion to permit amendment of complaint applies to  2255 petitions insofar as a district court may in its discretion permit an amendment to a petition to provide factual clarification or amplification after the expiration of the oneyear period of limitations as long as the petition itself was timely filed and the petitioner does not seek to add an entirely new claim or new theory of relief holding that the 2010 amendment was a clarification