a $302 million settlement, the largest ever paid by a medical lab company for a faulty product. A subsidiary of Quest, Nichols Institute Diagnostics Inc., was charged with marketing and selling faulty blood test kits to medical testing lab companies over a period of six years, despite substantial evidence that the product obtained inaccurate results. The "qui tam" case, which was brought under the False Claims Act by a California biochemist, launched a large-scale federal investigation and resulted in the record-setting resolution. The whistleblower was awarded $45 million of the $262 million civil settlement under the False Claims Act. In April 2009, the aerospace and defense technology company, Northrop Grumman, settled a lawsuit brought by a whistleblower and the US government alleging that the company sold faulty electronic equipment to the government for military satellites. The $325 million settlement remains the largest ever paid by a defense contractor in a qui tam case. Under the False Claims Act, which requires the government to award whistleblowers 15-25% of recoveries, the whistleblower Robert Ferro received $48.7 million for his participation in the case. In May 2004, Warner-Lambert agreed to settle claims brought in Franklin v. Parke-Davis by whistleblower David Franklin under the False Claims Act that the company had engaged in off-label promotion of the drug Neurontin. At the time, the $430 million settlement was one of the largest pharmaceutical settlements in history and the first off-label promotion case successfully brought under the False Claims Act. In October 2011, Pfizer agreed to settle all civil claims in a whistleblower suit brought under the False Claims Act in connection with off-label promotion of the drug Detrol. The settlement was $14,500,000. Canada In the provinces of Canada that observed the English common law, the qui tam action has had limited scope, although as recently as 1933 the Exchequer Court Act, R.S.C. 1927, c. 34 had language to the effect that qui tam was permitted in "suits for penalties or forfeiture as where the suit is on behalf of the Crown alone." (Bank of Montreal v. Royal Bank of Canada, [1933] SCR 311; see sec 75(a) of RSC 1886 v2 c.135 "Supreme and Exchequer Courts"). Lawyers have used the qui tam action to prevent unwarranted intrusion into their domain by unqualified practitioners (1871: Allen Qui Tam v. Jarvis, 32 UCR 56). In cases like these, it would appear that the Crown is owed a bond