Digital Realty Trust, Inc. v. Somers

Somers (plaintiff) sued Digital Realty (defendant) under Dodd-Frank's whistleblower anti-retaliation provision after being fired for internally reporting suspected securities-law violations to management, without ever reporting to the SEC; Digital Realty moved to dismiss, arguing Dodd-Frank's definition of whistleblower required reporting to the SEC, but the district court and Ninth Circuit both found the statute ambiguous and deferred to an SEC rule extending protection to purely internal disclosures required or protected under a separate statute, the Sarbanes-Oxley Act.