In this task, you will be shown a prompt from a judicial decision and multiple holding statements derived from citations following text in a legal decision. Holdings represent the governing legal rule when the law is applied to a particular set of facts. There are five answer choices for each citing text. The correct answer is the holding statement that corresponds to the citing text. You should write an incorrect option. Even though there exist multiple wrong answers, we only need a single wrong answer. There is a <HOLDING> token in the position of the citing text prompt where the holding statement was extracted.

[Q]: of common law fraud, it is considered a fraudulent act and is protected by 9(b)). We conclude that 9(b) applies to FCA fraud claims because not only is such a conclusion in accord with other courts and our more recent decisions, but also because its applicability is consistent with the purposes of Rule 9: (1) to inhibit claims that are filed as a pretext to uncover unknown wrongs; (2) to protect defendants from the harm that results from charges of serious wrongdoing; and (3) to give defendants notice of the complained-of conduct, enabling defendants to prepare a defense. Coronet Insurance Co. v. Seyfarth, 665 F.Supp. 661, 666 (N.D.Ill.1987). See also U.S. ex rel. Stinson, Lyons, Gerlin & Bustamante v. Blue Cross Blue Shield of Georgia, Inc., 755 F.Supp. 1055, 1058 (S.D.Ga.1990) (<HOLDING>); U.S. ex rel. Stinson, Lyons, Gerlin &
Holding statements: (A) holding a broad claim with no factual support was insufficient to satisfy rule 9b (B) holding that rule 9b applies to fca (C) holding that californias ucl claims are subject to rule 9b pleading standards (D) holding that charge of money laundering need not satisfy rule 9b (E) holding plaintiffs speculations did not satisfy rule 9b requirements
[A]: holding a broad claim with no factual support was insufficient to satisfy rule 9b

[Q]: pain and suffering, demonstrated his reliance on a prohibited tort theory); Strock v. Pressnell, 38 Ohio St.3d 207, 527 N.E.2d 1235, 1242-43 (1988) (declining to consider an intentional infliction of emotional distress action, in which the plaintiff sought damages for "anguish, shock, nervousness, and depression," because the abolition of claims for alienation of affections was intended to preclude these allegations); see also Wilson v. Still, 819 P.2d 714, 716 (Okla.1991) (finding a suit for intentional infliction of emotional distress was barred because the plaintiff basically sued the defendant for "wil-fully taking away her husband" and stating the legislature immunized that conduct from tort liability). But see Erickson v. Christenson, 99 Or.App. 104, 781 P.2d 383, 385-86 (1989) (<HOLDING>), appeal dismissed, 311 Or. 266, 817 P.2d 758
Holding statements: (A) holding that a tort claim for intentional infliction of emotional distress is distinct from a claim for emotional distress damages under the employment discrimination statute (B) holding a plaintiff could proceed on a claim alleging intentional infliction of emotional distress because the alleged losses were different from those for seduction but also stating plaintiffs previously suing for seduction could recover for damage to character and reputation as well as for mental anguish and pecuniary losses (C) recognizing validity of cause of action for intentional infliction of emotional distress (D) holding that police officers were immune from liability for damages resulting from alleged intentional infliction of emotional distress (E) recognizing the tort of intentional infliction of emotional distress
[A]: holding that a tort claim for intentional infliction of emotional distress is distinct from a claim for emotional distress damages under the employment discrimination statute

[Q]: based on whether KSU had the authority to waive Eleventh Amendment immunity. See Ford Motor Co., 323 U.S. at 467, 65 S.Ct. 347. We easily resolve this question by examining the enabling legislation, Kan. Stat. Ann. 76-723. Nothing in the statute itself makes entering into a contract waiving immunity an ultra vires act. Indeed the contrary is true-this legislation explicitly gives KSU, as a state educational institution, expansive, unlimited authority to contract with the DOE so that KSU may participate in student financial assistance programs. Further, unlike in other Kansas statutes, there is no provision in 76-723 disclaiming a waiver or prohibiting consent to waive. See, e.g., Kan. Stat. Ann. 75-6116(g) ( ement Co. (In re Estate of Fernandez), 123 F.3d 241, 244-46 (5th Cir.) (<HOLDING>), amended by 130 F.3d 1138 (5th Cir.1997); cf.
Holding statements: (A) holding that the alien tort statute itself is not a waiver of sovereign immunity (B) holding that the united states is liable for interest only in the event of a clear statutory waiver of sovereign immunity (C) holding that the waiver of sovereign immunity must be clear and unequivocal (D) holding attempted statutory waiver of sovereign immunity under 106a unconstitutional and listing similar cases (E) holding that section 106a mandates an automatic waiver of sovereign immunity and thereby impliedly repeals the ftcas exhaustion requirement
[A]:
holding that the alien tort statute itself is not a waiver of sovereign immunity