False Claims Act: Implied Certification Theory
A Minnesota district court issued a preliminary injunction against a former franchisee who engaged in a competing business during the franchise relationship. Snap Fitness, Inc., a gym franchisor, entered into a franchise...more
Recently, the Industrial and Commercial Bank of China Ltd. (“ICBC”) entered into two consent orders. The first consent order is with the New York State Department of Financial Services (the “NYDFS”) for alleged deficiencies...more
I thought Frosty was a good analogy to consider the disgraced Goldman Sachs Group Inc.’s former partner Tim Leissner, as he is certainly back again. Yesterday, I begin a two-part blog post series on Leissner’s settlement with...more
This week I will be considering the recent spate of Foreign Corrupt Practices Act (FCPA) enforcement actions brought by the Securities and Exchange Commission (SEC) at the close of its fiscal year. Last week saw several...more
Last week Juniper Networks, Inc. (JNPR) resolved their long-standing Foreign Corruption Practices Act (FCPA) enforcement action by settling with the Securities and Exchange Commission (SEC) via a Cease and Desist Order...more