OPINION
GOULD, Circuit Judge:
This case involves a group of Filipino World War II veterans and their widows who did not receive payments under the Filipino Veterans Equity Compensation Fund ("FVEC"), a fund established by statute in 2009 to give a one-time payment to each qualifying service member. These veterans and their widows either: (1) were ineligible for benefits under the statute; or (2) qualified for benefits, but were denied them because the Department...
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