Cir.1994). 29 . See, e.g., Karvelas, 360 F.3d at 224-25. 30 . See S. Prawer and Co., 24 F.3d at 326 (quoting United States ex rel. Springfield Terminal Ry. Co. v. Quinn, 14 F.3d 645, 651 (D.C.Cir.1994)) 31 . For a more detailed history of the FCA, see, for example, S. Prawer and Co., 24 F.3d at 324-26, and United States ex rel. LaValley v. First Nat’l Bank of Boston, 707 F.Supp. 1351, 1354-56 (D.Mass. 1988). 32 . See S. Prawer and Co., 24 F.3d at 325. 33 . Id. (quoting 31 U.S.C. § 3730(b)(4) (amended by 31 U.S.C. § 3730(e)(4))). 34 . See United States ex rel. Cantekin v. Univ. of Pittsburgh, 192 F.3d 402, 408 (3d Cir.1999). 35 . Id. 36 . S. Prawer and Co., 24 F.3d at 325. 37 . See id. at 325-26; see also United States ex rel. State of Wisconsin v. Dean, 729 F.2d 1100 (7th Cir.1984) (<HOLDING>). 38 . See S. Prawer and Co., 24 F.3d at 326 ("
holding that under federal law the party seeking to obviate the forum selection clause must prove that the inclusion of the clause was the result of fraud or coercion  fraud in the inducement as to the entire contract is not enough holding that under the pre1986 jurisdictional limitation a claim by the state which discovered the fraud investigated the fraud disclosed the fraud to the federal government and which was the original source of the information was jurisdictionally barred holding that the issue of fraud was precluded because the previous jury necessarily considered fraud as the basis for chapter 93a liability recognizing attempted fraud as a lesserincluded offense of fraud in violation of article 14 for the government of the navy holding that a plaintiff cannot avoid the securities fraud exception by pleading mail fraud or wire fraud if the conduct giving rise to those offenses also amounts to securities fraud