the requirement that the defendant had ‘knowledge’ of the alleged falsity”). Here, the complaint alleges that Honeywell cherry-picked the data it disclosed to Armor Holdings and to the public so that it could continue to sell Z Shields. (Compl. ¶¶ 4-5.) Thus, the complaint alleges not merely objective scientific disagreement as to the findings of the various tests Honeywell conducted, but Honeywell’s bad faith in selectively disclosing those findings. See supra 1(C). Moreover, the complaint alleges that Honeywell did so “knowingly.” (Compl. ¶ 91.) Pleading that a defendant “knowingly misrepresented and concealed facts” satisfies the falsity requirement under 31 U.S.C. § 3729(a)(2). United States ex rel. Westrick v. Second Chance Body Armor, Inc., 709 F.Supp.2d 52, 56 (D.D.C. 2010) (<HOLDING>); see also Fed.R.Civ.P. 9(b) (providing that
holding that there was no jurisdictional defect when the language of the charging document tracked the statutory language even though the facts proffered at the plea hearing were insufficient to establish that the defendant committed the crime holding that the court may consider an article not attached to the complaint in determining whether to dismiss the complaint because the article was integral to and explicitly relied on in the complaint and because the plaintiffs did not challenge its authenticity holding that the complaint pled a claim under the unamended  3729a2 in part because it tracked the language of the statute holding that an indictment under  922g1 was not required to allege a substantial effect on interstate commerce an indictment which tracked the statutory language was sufficient holding that once a plaintiff has pled facts in the complaint indicating that the statute of limitations is a complete or partial bar to an action it is incumbent upon the plaintiff to plead either in the complaint or in amendments to it facts establishing an exception to the affirmative defense