Protecting Government Defense Contracting with a Purpose: Interpreting Civil Liability Under the Anti-Kickback Act

The Department of Defense awards over $600 billion in government defense contracts to private contractors every year. The magnitude of these awards and the structure of defense contracts place the government at serious risk if fraud and misrepresentation are not adequately regulated and prosecuted. The Anti-Kickback Act of 1986 seeks to protect the government from fraud by imposing damages on prime contractors that either accept kickbacks or include the cost of kickbacks in their contract prices. The Act’s civil liability provision provides for direct and vicarious liability against prime contractor corporations whose employees or subcontractors engage in kickback activity. Recently, conflicting interpretations have surfaced regarding the extent of vicarious liability damages under the Act’s civil liability provision. This Note argues that the textual ambiguity and inconclusive legislative history surrounding the civil liability provision require that the provision be interpreted and applied in light of the Act’s purpose and goals. Accordingly, this Note argues that the civil liability provision should be interpreted to limit vicarious liability damages against prime contractor corporations. This interpretation satisfies the Act’s purpose and goals and avoids the substantial risks created by expanding vicarious liability damages. Most significantly, limiting vicarious liability damages appropriately protects the government’s interest, maintains the role of prime contractor corporations, and preserves the market for government defense contracts

The State of Federal Bankruptcy Law: The Ninth Circuit\u27s Debt Recharacterization Analysis in \u3cem\u3eIn re Fitness Holdings International\u3c/em\u3e

On April 30, 2013, the U.S. Court of Appeals for the Ninth Circuit in In re Fitness Holdings International, Inc. held that bankruptcy courts have the authority to recharacterize debt as equity when the obligation does not constitute a “right to payment” under state law. In so holding, the court adhered to a state law approach and declined to adopt a federal rule for debt recharacterization, thus creating a split amongst the federal appeals courts. This Comment argues that the Ninth Circuit’s state law approach is more desirable than promulgating a federal debt recharacterization rule because state law is more predictable and guarantees that a property interest will receive the same protections in federal bankruptcy courts as it would in state courts. This Comment also argues that a state law approach is preferable because it is rooted in precedent and avoids the risk that bankruptcy courts will infringe on substantive state policy

Computer aided manual validation of mass spectrometry-based proteomic data

Advances in mass spectrometry-based proteomic technologies have increased the speed of analysis and the depth provided by a single analysis. Computational tools to evaluate the accuracy of peptide identifications from these high-throughput analyses have not kept pace with technological advances; currently the most common quality evaluation methods are based on statistical analysis of the likelihood of false positive identifications in large-scale data sets. While helpful, these calculations do not consider the accuracy of each identification, thus creating a precarious situation for biologists relying on the data to inform experimental design. Manual validation is the gold standard approach to confirm accuracy of database identifications, but is extremely time-intensive. To palliate the increasing time required to manually validate large proteomic datasets, we provide computer aided manual validation software (CAMV) to expedite the process. Relevant spectra are collected, catalogued, and pre-labeled, allowing users to efficiently judge the quality of each identification and summarize applicable quantitative information. CAMV significantly reduces the burden associated with manual validation and will hopefully encourage broader adoption of manual validation in mass spectrometry-based proteomics.National Institutes of Health (U.S.) (Grant R24DK090963)National Institutes of Health (U.S.) (Grant U54CA112967)National Cancer Institute (U.S.). Integrative Cancer Biology Program (Fellowship)Charles S. Krakauer FellowshipHugh Hampton Young Fellowshi

Complex phylogeographic history of central African forest elephants and its implications for taxonomy

Background: Previous phylogenetic analyses of African elephants have included limited numbers of forest elephant samples. A large-scale assessment of mitochondrial DNA diversity in forest elephant populations here reveals a more complex evolutionary history in African elephants as a whole than two-taxon models assume. Results: We analysed hypervariable region 1 of the mitochondrial control region for 71 new central African forest elephants and the mitochondrial cytochrome b gene from 28 new samples and compare these sequences to other African elephant data. We find that central African forest elephant populations fall into at least two lineages and that west African elephants (both forest and savannah) share their mitochondrial history almost exclusively with central African forest elephants. We also find that central African forest populations show lower genetic diversity than those in savannahs, and infer a recent population expansion. Conclusion: Our data do not support the separation of African elephants into two evolutionary lineages. The demographic history of African elephants seems more complex, with a combination of multiple refugial mitochondrial lineages and recurrent hybridization among them rendering a simple forest/savannah elephant split inapplicable to modern African elephant populations

Multi-ancestry transcriptome-wide association analyses yield insights into tobacco use biology and drug repurposing

Most transcriptome-wide association studies (TWASs) so far focus on European ancestry and lack diversity. To overcome this limitation, we aggregated genome-wide association study (GWAS) summary statistics, whole-genome sequences and expression quantitative trait locus (eQTL) data from diverse ancestries. We developed a new approach, TESLA (multi-ancestry integrative study using an optimal linear combination of association statistics), to integrate an eQTL dataset with a multi-ancestry GWAS. By exploiting shared phenotypic effects between ancestries and accommodating potential effect heterogeneities, TESLA improves power over other TWAS methods. When applied to tobacco use phenotypes, TESLA identified 273 new genes, up to 55% more compared with alternative TWAS methods. These hits and subsequent fine mapping using TESLA point to target genes with biological relevance. In silico drug-repurposing analyses highlight several drugs with known efficacy, including dextromethorphan and galantamine, and new drugs such as muscle relaxants that may be repurposed for treating nicotine addiction

Direct single-enzyme biomineralization of catalytically active ceria and ceria-zirconia nanocrystals

Biomineralization is an intriguing approach to the synthesis of functional inorganic materials for energy applications whereby biological systems are engineered to mineralize inorganic materials and control their structure over multiple length scales under mild reaction conditions. Herein we demonstrate a single-enzyme-mediated biomineralization route to synthesize crystalline, catalytically active, quantum-confined ceria (CeO2–x) and ceria–zirconia (Ce1–yZryO2–x) nanocrystals for application as environmental catalysts. In contrast to typical anthropogenic synthesis routes, the crystalline oxide nanoparticles are formed at room temperature from an otherwise inert aqueous solution without the addition of a precipitant or additional reactant. An engineered form of silicatein, rCeSi, as a single enzyme not only catalyzes the direct biomineralization of the nanocrystalline oxides but also serves as a templating agent to control their morphological structure. The biomineralized nanocrystals of less than 3 nm in diameter are catalytically active toward carbon monoxide oxidation following an oxidative annealing step to remove carbonaceous residue. The introduction of zirconia into the nanocrystals leads to an increase in Ce(III) concentration, associated catalytic activity, and the thermal stability of the nanocrystals

ImaYDiT - Imagining young disabled people's transitions in a time of major societal change: Research project report

ImaYDiT was funded by DRILL – Disability Research for Independent Living and Learning. This is supported by the Big Lottery Fund. WiltsCIL staff, members of WiltsCIL CoproductionGroup and researchers at UWE came up with the original idea for this project. We wanted to support young disabled people to explore and re-imagine their adult lives and have the best future. This involved taking an ‘assets-based’ approach. This is where we focus on what people can do- rather than what they can’t do – which is a ‘deficit approach’. We also thought that there is not enough research about the whole of young disabled people’s lives. Instead a lot of research only concentrates on transitions through the benefits and service system.Wiltshire Social Services and the Wiltshire Parent Council helped steer the project because, where we could, we also wanted to put young disabled people’s hopes and dreams into action.We want to understand how this group of young disabled people can be supported to become the next generation who are aware of their rights, with ambitions for their futures and able to establish meaningful and independent adult lives

Next generation PCR microfluidic system

Stokes Bio, founded in 2005, develops innovative microfluidic technologies. In 2008 in collaboration with Monsanto, an application driven development for a high-throughput instrument in the detection and characterisation of Single Nucleotide Polymorphisms (SNPs) in agricultural crops was initiated. Stokes technology is designed to generate aqueous nanolitre scale droplets of reagents and samples, wrapped in a carrier fluid from standard microtitre plates and to mix them using Stokes Bio’s proprietary liquid bridge mixers. Following mixing the complete assay is transferred in the carrier fluid through the use of a continuous flow system, to a flow through thermal cycler and an optical reading station. This poster summarises results collated using the Stokes Bio genotyping platform currently based in Monsanto. Data will be presented to illustrate the dynamic capabilities of the instrument, highlighting the enhanced sensitivity and reproducibility of PCR in droplet format compared to well-based technologies

Economics methods in Cochrane systematic reviews of health promotion and public health related interventions.

Peer reviewedPublisher PD

Estimating actual foot size from a static bare foot print in a White British Population

In forensic intelligence-gathering it would be useful to be able to estimate the size of a perpetrator's foot from a standing bare footprint found at the scene of crime. Currently, the advice is to add a fixed amount to the length of the footprint (typically 1.5 or 2.0 cm), but there is little evidence for this approach. This study used measured footprint and actual foot lengths from 146 participants from the white British student population of a University in the UK. Data were analysed using multiple regression with foot length as the dependent (outcome) variable and footprint length and sex as the independent variable/factor respectively. Sex was not a significant predictor. The regression equation for the best estimate of the foot length is 19.89 + 0.95 × print length ± 8 mm