Because a whistleblower failed to exhaust her administrative remedies, a federal district court dismissed her Sarbanes-Oxley Act claim.  Newman v. Metro. Life Ins. Co., No. 12-CV-10078 (D. Mass. Jan. 21, 2015).  Prior to initiating a federal lawsuit under SOX, a whistleblower must file a complaint with OSHA and afford OSHA the opportunity to resolve the allegations administratively.  The whistleblower omitted from her OSHA complaint the names of all but one of the individual defendants named in her SOX action.  While district courts disagree as to whether a whistleblower must name each defendant as a respondent in the OSHA complaint or whether merely identifying each defendant as an actor within the body of the complaint is sufficient, here the whistleblower failed to identify all but one of the defendants at all.  As a result, she failed to exhaust her administrative remedies against all but one of the defendants.