As someone famously said, “We live in a material world.” After the Universal Health Services, Inc. v. United States ex rel. Escobar decision, this is particularly true in at least two ways.

In the whistleblower world, there is a pecking order of “haves” and “have nots. In one camp are the paid whistleblowers. In the other are the unpaid whistleblowers. In the paid whistleblower ranks, there are four or five different categories of potential claimants (e.g., SEC whistleblowers, IRS whistleblowers, and even Texas Parks and Wildlife whistleblowers), but the 800-pound gorilla is the False Claims Act/qui tam plaintiff. This is the statute where the huge awards are paid, some exceeding $100,000,000.