The market
$6.8B in FY2025 False Claims Act recoveries, a record. 1,297 qui tam filings, also a record, with 401 new government investigations. The DOJ and DHS Trade Fraud Task Force passed $1 billion in under a year. Perfectus Aluminum settled for $549.5 million, the largest civil customs settlement in the statute's history. Ceratizit settled for $54.4 million, with $9.75 million to a single relator. More targets than capacity, and the Department has said so.
The invitation
In April 2026 the Civil Division announced FOCUS, formally inviting data miners, already more than 45% of qui tam complaints since FY2024, to bring their signals. In mid-July it published the entry mechanism, a white-paper questionnaire, and made its Global Trade and Commerce Enforcement Section permanent. A federal agency published, in advance, the specification a screening engine must satisfy, then opened a door.
No relationship required
Section 3730(b)(1) is the entire standing test: a person may bring a civil action. Relators have been a competitor (Island Industries v. Sigma, an $8 million verdict trebled to almost $26 million), a trade association (Perfectus, a 17.5% whistleblower share potentially exceeding $96 million), and a purpose-formed investigative firm with no market position (Customs Fraud Investigations v. Victaulic, 839 F.3d 242). The question is not who you are. It is whether your analysis survives the public-disclosure bar.
The distinction that decides cases
Statistical anomaly and documentary contradiction are not the same asset. Courts dismiss the first and sustain the second. Forge does not produce anomalies. It produces contradictions: an entity asserts one thing in a government-facing document while a second document establishes another, both attached, the resolution path recorded, the statute cited. A complaint built on two documents and a traced ownership chain is a different pleading from a complaint built on an outlier.
The economics
Trebled duty damages are arithmetic, not argument, because origin and classification mechanically determine the rate. Per-entry-summary penalties run $14,308 to $28,619 per violation and compound past the damages on high-volume filers. Reckless disregard suffices; there is no specific-intent element. Materiality avoids the Escobar fight. Relator share is 15 to 25% where the government intervenes, 25 to 30% where it declines, with fees paid by the defendant.
The provenance ledger
Every input Forge ingests is stamped and classified by public-disclosure channel, so a finding carries a computed exposure score before it is ever filed. That converts the central risk of data-miner qui tam from a litigation gamble into a pre-filing calculation, and builds the original-source record contemporaneously rather than reconstructing it under attack.