In the first opinion on the subject by an appellate court, the U.S. Court of Appeals for the Fifth Circuit ruled in Asadi v. G.E. Energy (USA), LLC, No. 12-20522 (5th Cir. July 17, 2013), that Dodd-Frank’s protections against whistleblower retaliation (and the right to file a lawsuit claiming a violation) apply only to individuals who have provided information to the SEC. The plaintiff, who was working in the Middle East, was fired after he complained internally that GE Energy’s actions in Iraq may have violated the Foreign Corrupt Practices Act. The district court recognized that there could be a debate regarding whether the plaintiff was a “whistleblower” with a private right of action, but dismissed the case because the Dodd-Frank Act did not protect whistleblowing activity outside of the United States.