What would an architectural FCA case actually look like in litigation?

A genuinely open question the paper raises in §5.4 but does not answer. The implied-certification theory established in Universal Health Services v. Escobar (2016) extends FCA liability beyond deliberate fraud to certifications of compliance the institution has no infrastructure to verify. The doctrinal theory sits available for the architectural extension.

But: no FCA case has been brought, let alone settled, on a purely architectural fact pattern. What has prevented the architectural extension from being brought is not the legal theory but the absence of audit infrastructure on the institutional side capable of surfacing architectural failure as a documentable claim — exactly the absence the reviewer of an institution's data infrastructure encounters when she asks the question and finds it unanswerable.

This question matters because it conditions the §5.4 trajectory analysis. C-0025 documents the loaded conditions; Q-0040 asks what the firing event looks like in practice. Candidate answers from outside the paper would specify: which relator brings the case, on what fact pattern, against what institution, citing which compliance representations against which architectural reality, against the precedent stack established by Duke ($112.5M), Harvard-Anversa ($10M), and Dana-Farber ($15M, December 2025).

No existing Claim fully addresses this question. It is left open for working-group contribution.