Mao’s Kitchen Inc. v. Mundy, Case No.B233557, 2012 Cal. App. LEXIS 961 (Sept. 10, 2012): The court held that the California False Claim Act’s public disclosure jurisdictional bar applies only if the alleged disclosure is to a member of the public outside of the court system. Relying on analogous federal case law distinguishing between the government and the public domain, the court found that the following documents did not trigger application of the jurisdictional bar: (1) a confidential fee waiver application filed with the court; (2) a letter sent to the presiding judge’s office; and (3) deposition transcripts lodged with the court. As to the deposition transcripts, the court reasoned that lodged documents should be treated differently than filed documents because of the temporary and often voluminous nature of lodged documents.
26 Mar '13