Cases cited by Defendants are distinguishable. In In re Conners, which interpreted FRCP 20(a), several plaintiff credit card companies attempted to join in an action against one defendant. 125 B.R. 611, 612 (Bankr. S.D. Cal. 1991). The court found plaintiffs' issuance of separate credit cards to defendant through different banks was not the same transaction or occurrence. Id. at 614-15. In this case, however, one Plaintiff alleges the same group of Defendants used one system to defraud government entities. The operative facts underlying the alleged transactions, including the parties, are more logically related than those in In re Conners.
In DirecTV v. Loussaert, the Court held several defendants had not engaged in the same transaction or occurrence when they bought separate devices to intercept DirecTV's satellite transmission. 218 F.R.D. 639, 642 (D. Iowa 2003). The court found separate issues of fact for each defendant, such as whether each defendant intercepted the transmission. Id. at 642-43. Here, the same group of Defendants allegedly used the same system to make multiple false claims. There are more overlapping operative facts than in DirecTV, such as how the single system worked and how Defendants used it to make allegedly false claims to government entities. Also unlike DirecTV, here Plaintiff alleges Defendants had a company policy of making false claims.DirecTV held the defendants did not have a common purpose because they each acted independently for their own individual purposes. Id.

Other courts have adopted the approach of looking to the FRCP 13(a) standard when case law under the statute at issue does not establish the meaning of "transaction or occurrence." See, e.g., State Bd. of Equalization v. Harleston (In re Harleston), 331 F.3d 699, 702 (9th Cir. 2003) (applying the logical relationship test of FRCP 13(a) to interpret the phrase "transaction or occurrence" in 11 U.S.C. § 106); Schulman v. California (In re Lazar), 237 F.3d 967, 979 (9th Cir. 2001) (same); Pinkstaff v. United States (In re Pinkstaff), 974 F.2d 113, 115 (9th Cir. 1992) (same); In re Oil Spill by Amoco Cadiz, 491 F. Supp. 161, 168 (N.D. Ill. 1979) (looking to cases under Rule 13(a) to interpret "transaction or occurrence" in 28 U.S.C. § 1607(b)); In re Malone, 115 B.R. 252, 254 (Bankr. E.D. Cal. 1990) ("The limited case law addressing [28 U.S.C.] § 2415(f) does not elucidate on the meaning of the words `transaction or occurrence.' . . . However, the similarity between the language of § 2415(f) and Rule 13(a) suggests that the latter, although not necessarily controlling resolution of this issue, offers useful guidance.").

Other courts have found a series of events can be a single "transaction or occurrence" under FRCP 13(a). See, e.g., In re Malone, 115 B.R. at 254 (holding several student loans made to plaintiff by different lenders was "the same transaction" in the context of debt collection proceedings); In re Century Brass Prods., Inc., 58 B.R. 838, 845 (Bankr. D. Conn. 1986) (ruling a series of sales of the same type of product between the parties during a ten-month period was a "transaction or occurrence" under FRCP 13(a)).

In addition to FRCP 13, Rules 14 and 10 also contain the phrase "transaction or occurrence." Cases interpreting Rule 14 have given it a broad construction. See, e.g., Lasa Per L' Industria Del Marmo Societa Per Azioni v. Alexander, 414 F.2d 143, 146 (6th Cir. 1969) ("Rules 13 and 14 are remedial and are construed liberally. Both Rules 13 and 14 are `intended to avoid circuity of action and to dispose of the entire subject matter arising from one set of facts in one action, thus administering complete and evenhanded justice expeditiously and economically.'") (quoting Blair v. Cleveland Twist Drill Co., 197 F.2d 842, 845 (7th Cir. 1952)); Blais Constr. Co. v. Hanover Square Assocs.-I, 733 F. Supp. 149, 152 (N.D.N.Y. 1990) (likening the term "transaction" in FRCP 14 to the "`same general set of facts'" or the "`same core of facts'") (quoting United States v. Joe Grasso Son, Inc., 380 F.2d 749, 751-52 (5th Cir. 1967)); cf. Galt G/S v. Hapag-Lloyd AG, 60 F.3d 1370, 1374-75 (9th Cir. 1995) (finding two acts committed by two separate actors at different times were not the same "transaction or occurrence" under FRCP 14); Stewart v. Am. Int'l Oil Gas Co., 845 F.2d 196, 200 (9th Cir. 1988) (ruling two separate parties' sales of the same item were not the same transaction because the "basic facts" underlying each sale were different).
A Ninth Circuit case considered the reach of the "transaction or occurrence" test in relation to Rule 10's pleading requirements. Bautista v. Los Angeles County, 216 F.3d 837, 840-41 (9th Cir. 2000) (stating fifty-one plaintiffs who sought individual relief based on different types of discrimination had pleaded different transactions or occurrences and should have divided them into separate counts under FRCP 10(b)). But see id. at 842-43 (Reinhardt, J., concurring) (asserting the majority's statements on Rule 10 were dicta, and the standard for finding a "transaction or occurrence" is whether there is a logical relationship, a similarity of factual background, or a "`systematic pattern of events'") (quoting Coughlin v. Rogers, 130 F.3d 1348, 1350 (9th Cir. 1997)).
Courts have broadly construed "transaction or occurrence" when the phrase appears in federal statutes. See, e.g., In re Oil Spill by Amoco Cadiz, 491 F. Supp. at 168 (considering the logical relationship, similarity between issues of fact and law, and similarity of evidence needed to prove each claim when interpreting "transaction or occurrence" in 28 U.S.C. § 1607(b));Sea-Land Serv., Inc. v. United States, 493 F.2d 1357, 1371 (Ct. Cl. 1974) (applying the logical relationship test to the phrase "transaction or occurrence" in 28 U.S.C. § 2415(f) and concluding two separate contracts were a single transaction because they involved the same objects, were executed on the same day, and incorporated each other by reference).
FRCP 15(c) contains language similar, but not identical, to that in 31 U.S.C. § 3732(b). Rule 15(c) states an amended pleading relates back to the date of the original pleading when the claim arises from the "conduct, transaction, or occurrence" set forth in the original pleading. Courts have construed this language broadly. See, e.g., Markus v. Gschwend (In Re Markus), 313 F.3d 1146, 1150-51 (9th Cir. 2002) (stating the test is met "when the claim to be added will likely be proved by the same kind of evidence offered in support of the original pleadings" or by a "common evidentiary base") (emphasis added) (internal quotations omitted); Martell v. Trilogy Ltd., 872 F.2d 322, 325 (9th Cir. 1989) (holding the test under FRCP 15(c) is "whether the original and amended pleadings share a common core of operative facts so that the adverse party has fair notice of the transaction, occurrence, or conduct called into question") (emphasis added); New Bedford Capacitor, Inc. v. Sexton Can Co. (In re New Bedford Capacitor, Inc.), 301 B.R. 375, 378-80 (Bankr. D. Mass. 2003) (noting "`an underlyingcommon scheme or course of conduct which is the basis of the original action and links otherwise distinct transactions'" meets the conduct, transaction, or occurrence test of FRCP 15(c)) (emphasis added) (quoting Coan v. O G Indus., Inc. (In re Austin Driveway Servs., Inc.), 179 B.R. 390, 397 (Bankr. D. Conn. 1995)).
Several courts have broadly construed "transaction or occurrence" when it does not appear in a statute or FRCP. See, e.g., Sims v. United States Dep't of Health Human Servs. (In re TLC Hosps., Inc.), 224 F.3d 1008, 1012-13 (9th Cir. 2000) (holding a continuous system of payments and adjustments in different years by the Department of Health and Human Services under the Medicare system was, under the logical relationship test, "the same transaction" in a bankruptcy recoupment proceeding); Clark v. Taylor, 163 F.2d 940, 942-43 (2d Cir. 1947) (stating a "transaction" or "occurrence" is the "subject matter of a claim," the "central core of fact," or the "substantial identity" of the claim); Arnold v. Bache Co., 377 F. Supp. 66, 67-68 (M.D. Pa. 1973) (finding, with respect to FRCP 54, systematic stealing and embezzling from plaintiffs and other members of plaintiffs' class was "a single transaction or occurrence" and arose from "a single aggregate of operative facts") (internal quotation omitted). But see FDIC v. F.S.S.S., 829 F. Supp. 317, 322 (D. Alaska 1993) (ruling three promissory notes between the same parties were not the same transaction or occurrence when they were created approximately ten years apart).
Additional federal statutes and regulations contain the phrase "transaction or occurrence" or similar language, but the cases do not shed light on the meaning of the phrase. See, e.g., 28 U.S.C. § 1330(c) (1993); 28 U.S.C. § 1368 (West Supp. 2004); 28 U.S.C. § 3012 (1994); 29 U.S.C. § 1854(f) (1999); 12 C.F.R. § 263.22(a) (2004).