FOCUS COLUMN
By Mandana Massoumi and Joel O'Malley The 9th Circuit Court of Appeals took its first foray recently in Van Asdale v. International Game Technology, 2009 DJDAR 12023, into what a plaintiff must show to establish a whistleblower claim under the Sarbanes Oxley Act, 18 U.S.C. Section 1514A. The court found the plaintiffs did not have to "prove the existence of [actual] fraud before suggesting the need for an investigation." Rathe...
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