Due attention has been paid to the effort by International Game Technology to have the Ninth Circuit Court of Appeals reverse a jury verdict, awarding $4.6 million to two former in-house patent attorneys who had brought whistleblower claims under the Sarbanes-Oxley Act of 2002. The two attorneys allegeg they were fired after they raised concerns about possible shareholder fraud. But other recent developments are defining the contours of whistleblower protections.

Section 922 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, enacted on July 21, 2010, created new protections and incentives for corporate whistleblowers that are codified as §21F of the Securities Exchange Act of 1934. The Dodd-Frank protections built upon the whistleblower safeguards established by SOX.

Pending Supreme Court decision

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