The following excerpt is from Bishop v. Wells Fargo & Co., 823 F.3d 35 (2nd Cir. 2016):
Although it would perhaps have been preferable for the district court to discuss its reasoning in dismissing these claims, the relators present no reason on appeal why their fraudulent inducement claim is distinct from their other claims and would not fail for the same reasons. Likewise, under the facts of this case, the relators cannot show a conspiracy to commit fraud given that they have not sufficiently pleaded fraud under the FCA. Their appellate briefing simply states that the district court failed to address their claims without providing any argument in support of the merits. Issues not sufficiently argued in the briefs are considered waived and normally will not be addressed on appeal.... [M]erely incorporating by reference an argument presented to the district court, stating an issue without advancing an argument, or raising an issue for the first time in a reply brief likewise did not suffice. Norton v. Sam's Club, 145 F.3d 114, 117 (2d Cir.1998).
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