As previously discussed, the United States Court of Appeals for the Second Circuit created a circuit split when it decided in Berman v. Neo@Ogilvy LLC, No. 14-4626 (2d Cir. Sept. 10, 2015) that whistleblowers need not report information to the SEC in order to seek protections under the Dodd-Frank anti-retaliation provisions. On October 14, 2015, the Second Circuit stayed the issuance of its mandate to allow the United States Supreme Court to decide whether it would take up the issue. However, on November 10, 2015, the defendants in the matter advised the Second Circuit that they would not be pursuing a writ of certiorari with the Supreme Court. Thus, the matter will be remanded to the district court for further proceedings.