An employee can gain such protections by making an internal report. This split is increasingly important in whistleblower cases due to the DFA’s provision doubling back pay awards for successful plaintiffs.[1]See U.S. ex rel. Williams v. Martin-Baker Aircraft Co., 389 F.3d 1251, 1261 (D.C. Cir. 2004) (citing Yuhasz v. Brush Wellman, Inc., 341 F.3d 559, 568 (6th Cir. 2003); United States ex rel. Ramseyer v. Century Healthcare Corp., 90 F.3d 1514, 1522-23 (10th Cir. 1996)). See also Stein v. Tri-City Healthcare Dist., 2014 U.S. Dist. LEXIS 121112 (S.D. Cal., Aug. 27, 2014) (“A compliance officer like Stein must prove that he went beyond his normal job duties to show that his employer knew he was engaging in protected activities.”).