Where third party’s qui tam claim was based upon independent information in addition to publicly disclosed documents, a public disclosure bar did not apply. The 7th U.S. Circuit Court of Appeals reversed a decision by U.S. District Judge Lynn S. Adelman, Eastern District of Wisconsin. Todd Heath filed a qui tam suit regarding the Educational Rate Program, a federal subsidy program authorized by the Telecommunications Act of 1996. The Federal Communications Commission established the Universal Service …