In the ongoing litigation against Columbia/HCA, the United States District Court for the District of Columbia held that a corporation may be liable under the False Claims Act for the acts of its employees or agents, even if the corporation receives no benefit from the fraudulent activity. In so holding, the court distinguished its opinion from decisions of other courts, holding that a corporation will only be liable under the False Claims Act if employees are acting (1) within the scope of their employment and (2) to benefit the corporation. The court noted that the amendments to the False Claims Act in 1986 undermined the reasoning of these earlier cases. The court also held that plaintiffs had plead certain claims with sufficient specificity to withstand a motion to dismiss.