Can a court award attorneys' fees against a plaintiff in a false claim under the False Claims Act?

In actions brought under the False Claims Act, a court may award attorneys' fees against the plaintiff if "the action was clearly frivolous, clearly vexatious, or brought primarily for purposes of harassment." 31 U.S.C. 3730(d)(4). An action is "clearly frivolous" when the result is obvious or the arguments made are "wholly without merit." Pfingston v. Ronan Eng'g Co., 284 F.3d 999, 1006 (9th Cir. 2002). Additionally, an action is "clearly vexatious" or "brought primarily for purposes of harassment" when the plaintiff pursues the litigation with an improper purpose, such as to annoy or embarrass the defendant. Id.