Since 2010, the public disclosure bar to a False Claims Act qui tam action (31 USC 3730) has applied to bar Federal False Claims Act suits only if (1) the disclosure at issue occurred through one of the channels specified in the statute; (2) the disclosure was public; and (3) the relator’s action is substantially the same as the allegation or transaction publicly disclosed.  The first element is satisfied only if the public disclosure occurs in one of these three channels:  Channel 1–a Federal criminal, civil, or administrative hearing in which the Government or its agent is a party.  Channel 2: a congressional, Government Accountability Office, or other Federal Report, hearing, audit, or investigation. Channel 3: a disclosure made in the news media.  This decision holds that an inter partes review of a patent before the Patent and Trademark Office isn’t one of the three channels.  The government is not a party to such a review and its purpose is not investigative.  Other public disclosures in this case in the right channels did not satisfy the third element–they didn’t disclose substantially the same facts on which the suit was based.