United States’ Notice of Election to Intervene for Purposes of Settlement and Motion to Unseal — United States ex rel. Forsyth v. Chroma Systems Solutions, Inc. (Dkt. 17, D. Mass.)

Summary

The United States' notice of election to intervene for purposes of settlement and motion to unseal in United States ex rel. Aidan Forsyth v. Chroma Systems Solutions, Inc., No. 25-cv-10052-ADB, in the U.S. District Court for the District of Massachusetts, filed October 20, 2025 as Document 17. Under the False Claims Act, 31 U.S.C. § 3730(b)(2) and (4), the United States intervenes solely to settle with Chroma, stating that the United States, the relator and Chroma executed a settlement agreement effective October 20, 2025 that resolves the action. It says a joint stipulation of dismissal will follow once Chroma pays, and asks the court to unseal the action, the relator's complaint and the notice. It is signed by Assistant U.S. Attorney Steven T. Sharobem.

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Case 1:25-cv-10052-ADB           Document 17        Filed 10/20/25      Page 1 of 2




                              UNITED STATES DISTRICT COURT
                               DISTRICT OF MASSACHUSETTS

                                                        )
UNITED STATES OF AMERICA                                )
ex rel. AIDAN FORSYTH,                                  )
                                                        )       No. 25-cv-10052-ADB
                         Plaintiff,                     )
          v.                                            )
                                                        )       UNDER SEAL
CHROMA SYSTEMS SOLUTIONS, INC.,                         )
                                                        )
                                                        )
                         Defendant.                     )
                                                        )


                UNITED STATES’ NOTICE OF ELECTION TO INTERVENE
               FOR PURPOSES OF SETTLEMENT AND MOTION TO UNSEAL

          Pursuant to the False Claims Act, 31 U.S.C. § 3730(b)(2) and (4), the United States

notifies the Court of its decision to intervene in this action solely for the purposes of settlement

with the defendant, Chroma Systems Solutions, Inc. (“Chroma”).

          The United States, the relator, and Chroma have executed a settlement agreement

effective October 20, 2025 (the “Settlement Agreement”), which resolves this False Claims Act

action. The United States and the relator will promptly file a Joint Notice of Stipulation of

Dismissal after Chroma has made payment pursuant to the terms of the Settlement Agreement.

          The United States respectfully requests that the Court unseal this action, the relator’s

Complaint, this Notice, and all pleadings filed thereafter. The United States further requests that

all other papers on file in this action prior to October 20, 2025, remain under seal because, in

discussing the content and extent of the United States’ investigation, the United States provided

such papers to the Court alone for the sole purpose of the Court’s evaluating whether it should

extend the seal. The relator assents to this motion to unseal. A proposed order is attached to this

notice.

       Case 1:25-cv-10052-ADB          Document 17         Filed 10/20/25    Page 2 of 2




Date: October 20, 2025                                      Respectfully submitted,

                                                            LEAH B. FOLEY
                                                            United States Attorney

                                                     By:    /s/ Steven T. Sharobem
                                                            STEVEN T. SHAROBEM
                                                            Assistant United States Attorney
                                                            United States Attorney’s Office
                                                            1 Courthouse Way, Suite 9200
                                                            Boston, MA 02210
                                                            (617) 748-3100
                                                            steven.sharobem@usdoj.gov


                                CERTIFICATE OF SERVICE
       I certify that, on October 20, 2025, I caused a copy of the foregoing document to be

served by e-mail on the following counsel (with counsel’s assent to electronic service):

                            NYSTROM BECKMAN & PARIS, LLP
                              One Marina Park Drive, 15th Floor
                                    Boston, MA 02210
                                      (617) 778-9100

                                      William C. Nystrom
                                 Email: wnystrom@nbparis.com

                                    Christine M. Kingston
                                 Email: ckingston@nbparis.com

                                SPIRO HARRISON & NELSON
                                363 Bloomfield Avenue Suite 2C
                                  Montclair, New Jersey 07042
                                        (973) 744-2100

                                          Eric H. Jaso
                                      ejaso@shnlegal.com



Dated: October 20, 2025                 By: /s/ Steven T. Sharobem
                                            STEVEN T. SHAROBEM
                                            Assistant United States Attorney


                                                2

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