that excluded a provision for delivery of all recording documents by Fidelity to the Navy, (2) the failure to secure recordation, and (3) the failure to sign forms necessary to perfect the Navy’s security interest. Atkinson conceded that the elements of the fraud theory concerning Fidelity’s alleged role were publicly disclosed. However, he claims that Penn Ship’s failure to record was not. The District Court held, and we agree, that the non-recording claim was based on public disclosures. Both the Navy’s response to then co-relator Schorsch’s FOIA request and a Department of Defense Office of the Inspector General Audit Report of March 25, 1994, (DoD IG Report) constitute public disclosures within the meaning of § 3730(e)(4)(A) and reveal the non-recor-dation. Mistick, 186 F.3d at 383 (<HOLDING>). Atkinson argues that his first allegation of
holding that a party attempting to compel arbitration must first establish that the dispute in question falls within the scope of a valid arbitration agreement holding that  514a preemption defense will not justify removal unless claim falls within the scope of erisas civil enforcement provision  502 holding that a response to a foia request falls within the scope of  3730e4as administrative  report provision holding that if a document falls within the scope of the public records statute then the presumption favoring disclosure applies holding issues within scope of administrative hearing are within the reviewing courts purview