The Fourth Circuit affirmed an award of emotional distress damages to a woman who was fired after raising concerns about a misstatement on one of her employer’s SEC filings, in violation of the anti-retaliation provision of the Sarbanes-Oxley Act. Jones v. SouthPeak Interactive Corp. of Delaware, et al., No. 14-1765 (4th Cir. Jan. 26, 2015). The SOX remedies provision contains two parts: first, a section stating that a successful claimant shall be entitled to “all relief necessary to make the employee whole”; and second, a section providing that compensatory damages “shall include” reinstatement, back pay, and compensation for special damages such as litigation costs, expert witness fees, and attorneys’ fees. The Fourth Circuit rejected defendant’s argument that “shall include” is the equivalent of “limited to,” and joined the Fifth Circuit and the Tenth Circuit in holding that emotional distress damages are available under the SOX anti-retaliation provision.