Christopher A. Feduccia v. I.C.E. Services, Inc., et al.

CourtDistrict Court, D. Alaska
DecidedNovember 21, 2025
Docket3:24-cv-00276
StatusUnknown

This text of Christopher A. Feduccia v. I.C.E. Services, Inc., et al. (Christopher A. Feduccia v. I.C.E. Services, Inc., et al.) is published on Counsel Stack Legal Research, covering District Court, D. Alaska primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Christopher A. Feduccia v. I.C.E. Services, Inc., et al., (D. Alaska 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ALASKA

CHRISTOPHER A. FEDUCCIA,

Plaintiff, v. Case No. 3:24-cv-00276-SLG I.C.E. SERVICES, INC., et al.,

Defendants.

ORDER RE MOTION TO DISMISS Before the Court at Docket 17 is Defendants Thomas J. Bourdon and I.C.E. Services, Inc.’s Motion to Dismiss Relator’s Complaint. Defendants assert that the Complaint should be dismissed with prejudice under Federal Rules of Civil Procedure 12(b)(6) and 9(b).1 The motion has been fully briefed.2 Oral argument was held on July 29, 2025.3 The Court has taken judicial notice of the following four documents that the Small Business Administration (“SBA”) released following the creation of the Paycheck Protection Program:

1 Docket 17-1 at 43. 2 Docket 21; Docket 26. 3 Docket 39. • First, the Court has taken judicial notice of SBA Form 3509’s PPP Loan Necessity Questionnaire (For-Profit Borrowers) dated October 2020 at

Docket 27-1.4 The questionnaire required recipients of PPP loans with an original principal amount of $2 million or greater to answer questions and provide documentation concerning the borrower’s business activity and liquidity.5 • Second, the Court has taken judicial notice of the SBA’s July 29, 2021

Frequently Asked Question (“FAQ”) 69 related to the PPP at Docket 30-2.6 FAQ 69 explains why the SBA discontinued the use of the Form 3509 (and Form 3510) Loan Necessity Questionnaire.7 • Third, the Court has taken judicial notice of the SBA’s December 9, 2020 PPP Loan FAQs.8 The SBA’s December 2020 FAQs contain answers to a

variety of questions concerning eligibility requirements for PPP loans.9

4 Docket 27 at 1. 5 Docket 27-1 at 2–10. 6 Docket 30-2. Docket 39. 7 Docket 30-2 at 1. 8 Docket 40. See U.S. Small Business Administration, Paycheck Protection Program Loans Frequently Asked Questions (FAQs) (Dec. 9, 2020), https://www.sba.gov/sites/default/files/2020- 12/Final%20PPP%20FAQs%20%28December%209%202020%29-508.pdf. Relator made an oral motion for judicial notice of this document during oral argument. Docket 39. Defendants did not oppose Relator’s request for judicial notice but assert that only FAQ Nos. 39, 46, and 53 are relevant to the claims and motion to dismiss in this case. Docket 38 at 2. 9 See U.S. Small Business Administration, Paycheck Protection Program Loans Frequently Asked Questions (FAQs). • Fourth, the Court has taken judicial notice of the SBA’s Form 2483 PPP Borrower Application Form as it existed in April 2020.10

For the reasons set forth below, the motion to dismiss will be granted and the Complaint dismissed with leave to amend with respect to Counts 1, 2, and 4. BACKGROUND The False Claims Act (“FCA”), 31 U.S.C. §§ 3729–3733, was enacted in 1863 to protect the federal government from false claims submitted by government contractors.11 “The FCA creates civil liability for ‘any person who (A) knowingly

presents, or causes to be presented, a false or fraudulent claim for payment or approval; [or] (B) knowingly makes, uses, or causes to be made or used, a false record or statement material to a false or fraudulent claim.’”12 “A private person, known as a qui tam relator, may bring a civil action under the FCA in the name of the U.S. government.”13 “The government may proceed with the action or decline

to take over the action; if the government declines, then the relator can still pursue the action.”14

10 The Court granted Relator’s oral motion for judicial notice of this document during oral argument. Docket 39. Docket 39. See U.S. Small Business Administration, Paycheck Protection Program Borrower Application Form, SBA Form 2483 (04/20) (Apr. 2020) https://home.treasury.gov/system/files/136/Paycheck-Protection-Program-Application-3-30- 2020-v3.pdf. 11 See Vt. Agency of Nat. Res. v. United States ex rel. Stevens, 529 U.S. 765, 781 (2000). 12 United States v. Allergan, Inc., 46 F.4th 991, 993 (9th Cir. 2022) (alteration in original) (quoting 31 U.S.C. § 3729(a)(1)). 13 Id. at 994 (citing 31 U.S.C. § 3730(b)). 14 Id. (citing 31 U.S.C. § 3730(b)(4)). In March 2020, Congress passed and the President signed the Coronavirus Aid, Relief, and Economic Security (“CARES”) Act.15 Section 1102 of that Act

amended the Small Business Act, 15 U.S.C. § 631 et seq., by creating the Paycheck Protection Program (“PPP”), a program providing forgivable loans to small businesses so as to permit those businesses to keep their employees on their payroll, rather than lay them off during the COVID-19 pandemic.16 A business seeking a PPP loan had to certify in good faith “that the uncertainty of current

economic conditions makes necessary the loan request to support the ongoing operations of the eligible recipient” and “that [PPP] funds will be used to retain workers and maintain payroll or make mortgage payments, lease payments, and utility payments.”17 Only small businesses that “employ[ed] not more than the greater of” “500 employees” or a “size standard in number of employees established by the [SBA] for the industry in which the business . . . operates” were

eligible to apply for PPP loans.18 Following the enactment of the CARES Act, the SBA created a PPP Borrower Application form that included a requirement that the applicant certify that “[c]urrent economic uncertainty makes this loan request necessary to support the ongoing operations of the Applicant” and a certification that “the information

15 Pub. L. No. 116-136, 134 Stat. 281 (2020). 16 Id. § 1102. 17 15 U.S.C. § 636(a)(36)(G)(i)(I–II) (enacted by CARES Act § 1102(a)(2)). 18 15 U.S.C. § 636(a)(36)(D)(i). provided in [the] application and the information provided in all supporting documents and forms is true and accurate in all material respects.”19

During 2020 and 2021, the SBA published multiple guidance documents, questionnaires, and “FAQs.”20 In late April 2020, the SBA clarified that borrowers must consider "their current business activity and their ability to access other sources of liquidity sufficient to support their ongoing operations in a manner that is not significantly detrimental to the business."21 On May 13, 2020, the SBA

advised PPP borrowers of its intent to review each loan greater than or equal to $2 million to determine whether the borrower had an adequate basis for making the required necessity certification.22 On December 17, 2024, Relator Christopher Feduccia initiated this FCA action on behalf of the United States against I.C.E. Services, Inc. (“I.C.E.”) and Thomas J. Bourdon, the President and CEO of I.C.E. Services (collectively,

19 Docket 1 ¶¶ 29–30 (quoting SBA Form 2483, supra note 10, at 2). 20 See Docket 1 ¶¶ 25, 27, 28. 21 Docket 1 ¶ 25 (citing U.S. Small Business Administration, Paycheck Protection Program Loan Necessity Questionnaire, Frequently Asked Questions (FAQs) (Jul.

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Christopher A. Feduccia v. I.C.E. Services, Inc., et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/christopher-a-feduccia-v-ice-services-inc-et-al-akd-2025.