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GoodearlandAldr edVersus Hughes Aircraft: A Whistle-Blo wingCase Study K evin W.Bowyer Department ofComputer ScienceandEngineering Univer sityofSouth Florida T ampa, Florida 33620-5399 [email protected] Abstr act–Whistle-blowing isacor etopic forany ”ethics” or ”pr ofessionalism” courseoffer ed for IS/CS/CE/EE ma- jor s.This paper documents areal whistle-blowing casethat is ideal foruse inteac hing .The incident isset inthe com- puting industry ,speci cally inthe supply ofmicr o-electr onic c hips foruse insafety-critical systems.Theincident iswell documented, withdecisions inboth acriminal caseanda civil case.Ittouc hes onall the major issuesinvolved in whistle-blowing . 1.Intr oduction The term “whistle blowing” maynotalready befamil- iar tostudents inIS/CS/SE/EE. Oneauthor de ned whistle blo wers as“those who…mak erevelations meanttocall attention tonegligence, abuses ordangers thatthreaten the public interest. Theysound analarm basedontheir expertise or inside knowledge, oftenfromwithin thevery organization in which theyw ork …Most [whistle blowers] knowthat their alarms poseathreat toanyone whobene ts fromtheongo- ing practice andthat their own careers andlivelihood may be atrisk” [5]. Examples ofsituations thatlead towhistle blo wing arewhen anemplo yeedisco vers that their compan y is kno wingly supplying anunsafe product tocustomers, or when someone discovers that taxdollars arebeing wasted in some fraudulent or agrant manner.The case discussed here actually combines bothofthese types ofconcerns. Whistle-blo wingismentioned inall the major codesof ethics relevant tothe computing profession. For example, the rst item inthe IEEE code(seechapter 3of [6], also www.ieee.org )says thatmembers agreeto: Accept responsibility inmaking engineering deci- sions consistent withthesafety ,health, andwel- far eof the public, anddisclose promptly factors that might endang erthe public orthe envir onment. The explanation ofitem 1.2ofthe ACM code (seeappendix 2 of [6]), “A void Harm toOthers, ”ampli es onthis theme: In the work envir onment thecomputing profes- sional hastheadditional obligationtoreport any signs ofsystems dangersthat might result inseri- ous personal orsocial damage. If one’ ssuperior s do not acttocurtail ormitigate suchdang ers, it may benecessary to“blow thewhistle” tohelp corr ectthe problems orreduce therisk. The AITP Standards ofConduct (seechapter 3of [6], also www.aitp.org )includes thestatement thatmembers will: Ne ver misr epresent orwithhold information thatis g ermane toapr oblem orsituation ofpublic con- cern norwill Iallow anysuchknown information to remain unchalleng ed. Principle 1.4ofthe IEEE-CS/A CMSoftw areEngineering Code ofEthics states: Disclose toappr opriate persons orauthorities any actual orpotential dangertothe user ,the public, or the envir onment, thattheyreasonably believeto be associated withsoftwar eor related documents. It is clear from these quotes thatwhistle blowing isan impor – tant concern forprofessionals inthe computing industry.In f act, thecodes ofethics ofour professional societiesrequir e the professional toblo wthe whistle incertain circumstances. There arewell-kno wncase studies inwhistle-blo wing;for e xample, theNASA Challenger disaster[4,7,10]. But rel- ati vely few are setinthe conte xtof the computing industry. Perhaps thebest-kno wnisthe BAR Tincident ofthe early 1970s [1](see alsochapter 7of [6]). This paper presents a modern whistle-blo wingcasestudy involving twowomen who work edfor Hughes Aircraft andblewthe whistle on fraud intesting andcerti cation ofmicro-electronic chips used invarious weapons systems. Atime lineforthe main e v ents inthis case appears inFigure 1.The time lineisuse- ful inemphasizing tostudents thelength oftime thatitcan tak eto resolv ewhistle-blo wingcases. 198519901995 Aldred & Goodearl inform government investigators of the problems. Civil suit filed in May of 1990. Goodearl leaves Hughes. Aldred laid off. Time period of the fraud, as specified in criminal indictment. civil suit settled Aldred & Goodearl become aware of problems in chip testing and paperwork. Hughes criminal conviction in June of 1992. Government joins civil suit in December 1992. Figure 1:Time lineofmajor ev ents inthe Goodearl andAldred versus Hughes Aircraft whistle-blo wingcase. 2. The Context: ChipsandTesting This caseinvolv escomputer chipsmade atHughes Air- craft Compan y’sMicro-electronic CircuitDivision inNe w- port Beach, California duringthetime period ofapproxi- mately 1985through 1987.Theparticular chipsinvolv ed are called hybrids ,because theyuse both digital andana- log logic inasingle package. HughesAircraft would sell as man yas 100,000 hybridsperyear ,at prices ranging from $300 to$5,000 each.Thechips wereusedinavariety of sophisticated electronicssystems,suchasaircraft radarunits and missile guidance systems.Atleast 73different Depart- ment ofDefense programs wereinvolv ed, including theF- 14, F-15, F-16andF-18 aircraft (seeFigure 2),the Maverick, Phoenix andAMRAAM (Advanced Medium-Range Air-to- Air Missile) missiles, DIVADS, INTELSA Tand other sys- tems [3]. The results ofchip failures inthe eld could be v aried. Onepossible scenario thatwas suggested bytesti- mon yin the criminal trialwas that theradar usedbya ghter plane todirect itsweapons couldfail! Contracts tosupply chipstothe government would re- quire thatthechips passspeci ed qualityassurance tests. T ypical testswould involv echecking whetherthepackaged chip allowed anyleaks thatmight letmoisture gettothe chip, andchecking thechip forfailures afterbeing subjected to temperature cycling, constant acceleration, and/orshock. Hybrids thatfailed aparticular testwould either bediscarded or re-w orkedtocorrect thedefect. Bycontract, re-workwas not allowed forfailure ofcertain tests. Assurance thatthechips didindeed passthespeci ed tests would bemade through paperworktracking thetests performed andtheresults. Hughes usedadocument calleda “lot traveler” tokeep track ofthe sequence oftests andother operations performedoneach hybrid. Ruth Aldred was emplo yedbyHughes from1979 to 1988. (Hername was Ruth Ibarra atthe time theincident be gan; shelater married andhername changed toRuth Al- dred.) From1984to1988, shewas asupervisor forhybrid quality assurance. Mar garet Goodearl was emplo yedbyHughes from1981 to 1989. In1986, Goodearl becameasupervisor forseals processing (“seal”asinseal ofthe packaging ofthe chip) in the environmental testingareaatthe Newport Beach facility . She hadpreviously work edasassupervisor forassembly on the hybrid production oorandasasupervisor inthe hybrid engineering lab. 3. The Fraud andCover -Up Disco very and recognition ofthe fraud followed atypical scenario. Apparently smallanomalies inpaperw orkraised questions, theanswers tothe questions raisedmoreserious concerns andthecontinued reactiontothe questions con- rmed thefears ofthe whistle-blo wers.Oneaccount states – “Aldred saidshebecame aw are ofproblems atthe Hughes plant in1985, whenGoodearl, thennew to her job, askedAl- dred tolook over some paperw ork.When shebrought errors in the paperw orktothe attention ofher supervisors, shesaid she was told tokeep quiet about theproblem” [13]. The indictment forthe criminal trialinwhich Hughes was con victed ofconspirac yto defraud thegovernment summa- rizes theillegal activity as–“to defraud theDepartment of Defense bykno wingly anddeliberately producinghybrids that hadnotbeen tested inthe manner speci ed bycontract and thepertinent militaryspeci cations …,and tomak efalse statements, writingsandrepresentations ondocuments …” [3 ]. More speci cally ,the indictment statesthatHughes w ould –“skip required environmental testsoncertain hy- Figure2:F-16 resanAGM-88 HARM missile. An F-16 Fighting Falcon fromthe416th Flight Test Squadron Edwards AirForce Base, Calif., resanAGM-88 HARM missile during testing. TheF-16 isone ofthe weapons systemsinwhich thehybrid chipswereused. Testimon yat the criminal trial indicated thatchip failure inthe eld could causepilots tobe unable toaim their weapons. (U.S.AirForce Photo, photoby T om Reynolds, www.af.mil/photos ). brids forwhich thereweredelivery pressures orpriorities, ” “fraudulently testorconduct rework onhybrids contrary to contractual provisions” and“falsify essential documents that required alltests andprocedures (includingrework history) and theresults ofsuch teststobe carefully recorded” [3]. Much ofthe fraud was apparently implemented underthe immediate directionofDonald LaRue. Relevant items inthe indictment state: “From timetotime, defendant LaRuewould di- rect testoperators to,among otherthings: (a) skip certain testsorprocedures, but mark the(lot) tra veler asifperformed; (b)falsify travelers to sho whybrids passing testswhen thehybrids had in fact failed therequired tests;(c)perform un- documented andunauthorized rework without the tra velers re ecting therework actually performed, as required bycontract; (d)sign-of ftra velers be- fore tests were performed; (e)conduct testsand procedures outofsequence; and(f)short cuttem- perature cycling andother processes. In order tomeet production goals,Hughes (through LaRue)would alsocause signoffs on tra velers forthousands ofhybrids tobe forged by emplo yeeswhohadneither conducted norhad kno wledge ofthe tests orthe actual testresults, in kno wing violation ofgovernment contractual re- quirements. Onrepeated occasions, LaRuewould personally remove leak stickersplaced onhybrids that failed either the ne leak orgross leaktests, and would cause thetravelers forsuch parts tobe initially markedorsubsequently alteredtofraudu- lently represent thatthepart hadpassed suchtest … ” [3 ]. In news accounts atthe time thatthecriminal indictment w as announced, Hughesof cials downplayed theincident and denied thatanything wronghadtaken place. Onere- sponse was that theindictment was “disproportionate tothe alle ged activities” [11].Another was that “nosubstandard or defecti ve hardw arewas deli vered byHughes” [11]. 4. Whistle-Blo wing After failing toget Hughes management interestedin correcting theproblems, AldredandGoodearl reportedthe problems tofederal investigators inlate 1986. Oneaccount quoted Goodearl describing hermotivation forwhistle- blo wing asfollo ws–“I had nochoice …I’ve got three sons and adaughter ,and anyone ofthem could windupinthe military …and dead because ofthese badparts” [13]. The criminal indictment listsspeci c actsofintimidation and harassment toward thewhistle blowers [3]. In one in- stance, aHughes manager calledGoodearl intohisof ce and demandedtokno wwho was “the goddamn squealer.” In an- other instance, Goodearl was told todo the tests theway that LaRue wanted themdone, andto“get with theprogram. ” In yet another instance, LaRuetoldGoodearl to“stay aw ay from QA”(quality assurance) or“it would costherher job.” In yet another instance, aHughes manager toreupahand- written complaint byGoodearl andtold here “Ifyou ev er do an ything likethat again, Iwill reyour ass.” Ne ws accounts give various additional detailsrelated to intimidation andharassment. Itwas alle ged that thewhistle- blo wers were “harassed bymeans ofracial andsexual slurs and verbal comments, inaddition tophysical gesturesand menacing postures”andthat onedaywhen Goodearl left w ork she“found abutchered pig’shead inabro wn paper bag onthe hood” ofher car[8]. The Hughes defenselawyers dispute thatthepig’ shead incident actuallyhappened. Harassment todiscourage thewhistle-blo wersalsoex- tended totheir families. Aldred’shusband described one incident asfollo ws–“The worst part ofthis probably was when ourdaughter ,V icki, came intoourbedroom crying. She said she’dpick edup the phone andthat somebody had told herthat wewere deadmeat ifwe didn’ tlea ve this alone. She was alatch-k ey kid atthe time, soone ofthe investiga- tors (from theJustice Department) wound upworking asher bodyguard forafe w weeks” [13]. Goodearl was red (“laid off”) by Hughes Aircraft in 1989. Aldred hadleftHughes in1988, “after beingrelieved of all meaningful responsibilities andputinacubicle with nothing todo” [18].Goodearl leda“wrongful termination” la wsuit against Hughes andanumber ofindi vidual managers in June of1990. Thissuitwas apparently laterdropped infa- v or ofthe suit under theFalse Claims Act. The unemplo ymentandthegeneral strainonGoodearl contrib utedtothe breakup ofher marriage in1995. Shewas quoted assaying –“I went fromengineering work tobeing a housek eeper”[13]. 5. The Criminal Trial The indictment inthe criminal trialnamed twodefen- dants, Hughes Aircraft andDonald AnthonyLaRue [2]. The alle gations werethatthedefendants: willfully conspiredand agr eed …(1) todefr aud the Department ofDefense byknowingly anddeliber – ately producing hybridsthathadnotbeen tested in the manner speci ed bycontr actand theper- tinent military speci cations …and (2)tomak e false statements, writingsandrepr esentations on documents The trial lasted fourweeks, and“anumber ofHughes em- plo yees testi ed …about “wholesale cheatingonawide range” ofenvironmental tests”[16].On June 15,1992, ajury found Hughes Aircraft guiltyconspiring todefraud theU.S. go vernment. DonaldLaRuewas acquitted ofall char ges, ap- parently becausethejury belie ved that hisactions werethe result ofpressure onhim byhigher -level management. In October of1992, U.S.District JudgeMatthe wByrne ned Hughes Aircraft $3.5million. Hughes appealed thecriminal conviction and ne. The appeal was tak en asfar as the Supreme Court,but was de- nied. Results ofacriminal trialcanbepresented asevidence in arelated civil trial. Thusthecriminal trialinthis case nearly guaranteed thewhistle-blo werswould winaci vil suit. 6. Backgr ound:TheFalse Claims Act An important elementofthis case isthat itinvolv esthe use ofthe False Claims Act(FCA), anessential toolforwhis- tle blowers incases involving fraudonthe federal govern- ment. Aninformati ve video thatdeals withtheFalse Claims Act andwhistle-blo wing,andissuitable forclassroom use, is “Fighting Fraud:Citizen ActionandtheQui Tam Rem- edy .” This video isav ailable fromtheTaxpayers Against Fraud organization. Seetheir webpage atwww.taf.org . The FCA (31U.S.C. 3729-31) isafederal law which has been inexistence since1863. Itwas moti vated byfraud against thegovernment; themilitary atthat time was having serious problems withsuppliers cheatingonthe supply and price ofgoods. President AbrahamLincolnwas apparently an early backerof the law,and itwas kno wnasthe “Lincoln La w.” The law was created todiscourage fraudbyencouraging people toreport it.Under thislaw,pri vate citizens canbring a civil suit against someone thathasdefrauded thefederal go vernment. Thelegal term “quitam” isused todescribe such suits. Theprivate citizen thatbrings thesuit iskno wn as a“relator .” The FCA states thatarelator (whistle blower) may receive between 15and 25percent ofthe reco vered funds ifthe government choosestoparticipate inthe suit. If the government decidesnottoparticipate inthe suit, the whistle blower may receive between 25and 30percent ofthe reco very ,plus legal fees andexpenses. The FCA hadfallen intorelative non-use until1986, when Congress passedamendments tostrengthen thelaw and mak eit easier toapply .In 1985, thelast year before the amendments tothe law,the government recovered roughly $27 million fromcivil fraud suits. Thenumber ofcases led and theamount offunds recovered bythe government each year hasgrown quickly sincethen. Roughly $500million per year was reco vered in1997 through 1999!Thenum- ber ofcases pursued bythe Department ofJustice av eraged about 500peryear in1997 through 1999. SeetheDepartment ofJustice statistics postedinthe www.taf.org web pages formore detail. 7.The Civil Trial The civil trial was originally ledonMay 29,1990 by Goodearl, Aldred,andtheTaxpayers AgainstFraudorgani- zation. Aldredheardofthe FCA while watching arepresen- tati ve of alaw rm speak onatele vision talkshow. Aldred and Goodearl thencontacted the rm ofPhillips &Cohen, and determined thattheyshould have a good case. Under theprovisions ofthe FCA, thegovernment took o ver the case inDecember of1992. Thecivil suit was settled inSeptember of1996. Insettling thesuit, Hughes agreed topay $3,159,000 tothe United Statesgovernment, $891,000 tothe whistle-blo wers,and$450,000 tocover the attorne ys’fees andexpenses forthe whistle-blo wers.Inone part ofthe settlement agreement, Hughesassertsthatit“de- nies anywrongdoing orliability ofanykind withrespect to an ychar ge,alle gation orclaim asserted againstitin this civil action. ”One ofthe attorne yswho represented Goodearland Aldred was quoted assaying –“This completely vindicates Ruth AnnAldred andMargaret Goodearl whomade great personal andprofession sacri cestosee justice done.”[15 ] 8. Uses ofthis Case inTeaching This caseisgood forteaching purposes becausedecisions were reached inboth criminal andcivil court cases. Thus a reasonable amountofdetail isav ailable, interms ofreal f acts andconclusions. Also,thecase followswhat might be considered aclassic pattern inwhich thewhistle blowers dis- co ver afraud, arerebuffed inattempts tohandle itinside the compan y, lose/lea ve their jobs, under goturmoil intheir per- sonal lives, and arevindicated yearslaterthrough thecourt system. Interms ofthe legal resolution, itis tempting to say that Goodearl andAldred “won. ”Ho wever ,their experi- ence was not aneasy oneand a“the ywon” conclusion may tak etoo narro wavie wof the ev ents. Their lawyer summa- rized theimpact onthe whistleblo wersasfollo ws–“As a result orreporting Hughestothe authorities, theylost their jobs. Theywent through substantial periodsofunemplo y- ment. Theyunderwent alifestyle change.Idon’ tthink they w ould tellyou itwas apleasant experience. ”[12 ]Aldred and her husband endeduponwelf areatone point, before land- ing new jobs in1991 [17].Goodearl andherhusband ended up ling bankruptc ybecause theyhad trouble payingbills [17 ],and thestrain ofunemplo ymentand nancial problems “helped endtheir 20-year marriage” [13].Goodearl said–“I went from engineering work tobeing ahousek eeper” [13]. Ho wever ,in spite ofthe dif culties, thewhistleblo werssay the y“w ould doitall again” [13]. One method ofusing thiscase inteaching isto assign it as the topic ofaresearch paper.Students shouldbeable to nd various news accounts relatedtothis case. Agood paper should distinguish betweenthecriminal andcivil tri- als, explain therole ofthe FCA, andmight alsodiscuss how the speci cs ofthis case mesh withtheIEEE Ethics Com- mittee’ s“Draft guidelines forengineers dissenting onethical grounds” [9]. This casemight similarly beassigned toastu- dent tobe developed foranin-class presentation. Alternati vely ,this case could beused foraclass discus- sion. Oneapproach isto (1) ask students toread about the case prior toclass, perhaps withashort worksheet tocom- plete, (2)goover the IEEE Ethics Committee’ s“Draft guide- lines forengineers dissenting onethical grounds” inclass, and then (3)use theelements ofthe draft guidelines aspoints of departure fordiscussion. Acomplementary approachisto (1) ask students togo tothe web andread theIEEE Ethics Committee’ sdraft guidelines priortoclass, (2)outline the basics ofthis case forthe class, and(3)ask thestudents to analyze how the draft guidelines relatetothis speci cs of this case. Stillanother approach isto ask thestudents to read material andcomplete worksheets priortoclass, and use theworksheets asthe starting pointfordiscussion. Ex- ample worksheets forthis purpose canbefound onthe web site marathon.csee.usf.edu/˜kwb/nsf-ufe /. Another approach tousing thiscase isto present itto the class asaspeci c example ofwhistle-blo wingandtheFalse Claims Actinthe computing industry.This might bedone by (1) having theclass viewthe TAF video onthe False Claims Act, (2)then presenting thiscase tothe class, and(3)then ha ving theclass followup bywriting ashort paper either on a more recent case(e.g., [19])in the computing industrythat in volv esthe FCA, oron howthe draft guidelines forethical dissent relatetothis case. Additional modelex ercises and acti vities related towhistle-blo wingareav ailable atthe web site mentioned justabove, as well asashort revie wof the T AF video. 9.Discussion The ev entual costanddamage duetothe deli very ofchips whose testresults werefalsi ed willnever be kno wn. Be- cause thenumber ofpotentially defective chips delivered was so large, and theywere installed insystems alreadyinuse, the cost andlogistics ofrecalling andreplacing thechips was judged tobe impractical. Oneofthe lawyers was quoted as follo ws–“The yare out inthe eld anditwould bepro- hibiti vely expensi ve to tak ethese hybrids outofall the mis- siles andplanes theyare in… There isadded risk,but the go vernment hasnoalternati ve; the yjust can’taf ford toshut these systems down totak eall the hybrids outand testthem again” [14]. If students aretempted tothink suchcases arearare oc- currence, aweb search onsuits ledunder theFCA should quickly dispelthisnotion. For example, inMarch of2000, documents wereunsealed inawhistle-blo wingcase led by Nira Schw artzagainst TRW.Schw artzwork edinthe design of computer softwareforanti-missile systemsatTR W.The alle gation isthat TRWfalsi ed teststosho wthat thesystems passed wheninfact theyhad failed [19]. Industriesinwhich fraudhasbeen uncovered through the F alse Claims Act–health careanddefense aremajor areas – ha ve ar gued forchanges inthe law.In essence, thecompa- nies would liketo mak eit harder forwhistle blowers towin their cases, andtoreduce theamounts companies would have to pay when whistle blowers dowin their cases. In1998, there was abill before theCongress thatwould have drasti- cally weakened theFalse Claims Actbyraising thestandard of proof required andopening loopholes thatwould “pro- hibit suitsagainst mosthealth careproviders” [20].Spon- sors ofthis billwere representati ves Bill McCollum (R-Fla) and William Delahunt (D-Mass) andsenators ThadCochran (R-Miss) andErnest Hollings (D-SC).Additional attempts of this type willlikely beseen inthe future. Refer ences [1] R.M. Anderson, DividedLoyalties: Whistle-Blowing at B ART ,Purdue Research Foundation, 1980. [2] Amended FirstSuperseding Indictment,U.S.District Court forthe Central District ofCalifornia, CaseNum- ber CR-91-1022 (A),U.S.A. versus Hughes Aircraft Compan yand Donald AnthonyLaRue. [3] U.S. District Courtforthe Central District ofCalifor – nia, Case Number 90-2716 JGD(JRx), FirstAmended Complaint, U.S.A.ex. rel. Taxpayers AgainstFraud, Ruth AnnAldred andMargaret Goodearl versus Hughes Aircraft Company. [4] R.M. Boisjoly ,The Challenger disaster:moralrespon- sibility andtheworking engineer ,chapter 1in Ethical Issues inEngineering ,pages 6-14,D.Johnson, editor, Prentice-Hall, Englewood Cliffs,1991. [5] S.Bok, Themorality ofwhistle blowing, inComputer s, Ethics &Society ,M.D. Ermann, M.B.Williams and C. Gutierrez (editors),OxfordUniversity Press, New Y ork, 1990. [6] K.W .Bo wyer ,Ethics andComputing ,IEEE Press, 2000 (revised edition). [7] R.P.Fe ynman, Anoutsider’ svie wof the Challenger in- quiry ,Physics Today ,February 1988,pages 26-37. [8] C.Gewertz, Whistle-blo wersuit led against Hughes, Los Angeles Times ,February 24,1990. [9] IEEE Ethics Committee, Draftguidelines forengineers dissenting onethical grounds, www.ieee.or g/orga- nizations/committee/ethics/eth guid.html (accessed24 April 2000). [10] M.Maier ,A major malfunction… thestory behind the space shuttle challeng erdisaster ,case study video tapes, Organizational LeadershipProgram/Chapman Uni versity /333 N.Glassell Street/Orange, CA92866 / fax (714) 744-3899. [11] J.Mathe wsand S.Pearlstein, Hugheschargedwith fal- sifying testdata, TheWashington Post ,December 13, 1991. [12] D.Meinert, Hughestopay $4.05 million tosettle law- suit, TheSanDiego Union-T ribune ´, September 11, 1996. [13] Andre Mouchard, Whistle-blowerssettouse their re ward, TheOrang eCounty Register ,Wednesday , September 11,1996. [14] V. Muradian, Hughespays$4million tosettle 1990 whistleblo wersuit, Defense Daily,September 11, 1996. [15] H.F.Rosenthal Tw o Hughes Aircraft whistle-blo wers a w arded $891,000, TheAssociated Press,Tuesday , September 10,1996. [16] A.Pasztor ,Hughes Aircraft pays$4.5million toset- tle false-testing lawsuit, Wall Street Journal ,September 11, 1996. [17] H.Weinstein, Tw o Hughes whistle-blo werstosplit $891,000, LosAngeles Times ,September 11,1996. [18] U.S. Department ofJustice joinswhistle-blo wersin la wsuit against Hughes Aircraft seekingseveral hun- dred million dollars, Taxpayers AgainstFraudpressre- lease, December 15,1992. [19] Former engineer sayscompan yfak ed tests, TheTampa T rib une ,March 7,2000. [20] Amending False Claims Actcould openloopholes for fraud, TheTampa Trib une ,October 14,1998.

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