Eric P. Christofferson

False Claims Act

• Advised global pharmaceutical company in connection with an industry-wide DOJ False Claims Act investigation concerning alleged violations of the anti-kickback statute based on donations to patient-assistance charities, resulting in a favorable settlement and the dismissal of a parallel inquiry concerning two multiple sclerosis products.
• Advised global diagnostics company in connection with multiple state and federal investigations concerning equipment sales resulting in potential violations of the federal Anti-Kickback Statute, as well as federal and local false claims act violations, resulting in no enforcement action.
• Advised global medical-device company in connection with DOJ False Claims Act investigation concerning the contracting for capital equipment and potential violations of the Anti-Kickback Statute, successfully advocating for an intervention declination.
• Advised large regional medical provider in connection with a DOJ False Claims Act investigation concerning alleged medical billing overcharges, successfully negotiating a resolution without a Corporate Integrity Agreement.
• Advising medical-software company in connection with a DOJ False Claims Act investigation concerning possible manipulation of software settings that led to reimbursement of unnecessary medical services by Medicare and third-party payers.

FDCA

• Advised global pharmaceutical company in connection with an internal investigation concerning alleged FDCA violations resulting from manufacturing process deficiencies, including identifying specific remediation recommendations that the company implemented.
• Advised global medical-device company in connection with an internal investigation concerning alleged deficiencies in quality control for a particular product, including identifying specific remediation recommendations that the company implemented.
• Advised global pharmaceutical company in connection with an internal investigation concerning alleged off-label promotion by company sales representatives, including identifying specific remediation recommendations that the company implemented.

FCPA

• Advised global pharmaceutical company concerning an anticorruption investigation by DOJ involving a Middle Eastern subsidiary, successfully advocating for—and securing—a declination.
• Advised global telecommunications company concerning an anticorruption investigation by DOJ involving a Venezuelan subsidiary, including successfully negotiating a deferred prosecution agreement.

Securities

• Advised global pharmaceutical company in connection with SEC investigation concerning alleged insider trading of company securities, resulting in no action taken.
• Advised DME manufacturer in connection with SEC investigation concerning alleged material billing fraud, resulting in a no action letter.

Individual Representations

• Represented executive of global technology company in connection with criminal insider trading investigation, resulting in no charges.
• Represented executive of financial consulting company in connection with criminal market-manipulation investigation, resulting in no charges.
• Represented chief compliance officer of pharmaceutical company in connection with criminal fraud and kickback investigation, resulting in no charges.