In Lawson v. FMR LLC, the federal First Circuit Courts of Appeal held that the Sarbanes-Oxley Act (“SOX”) does not protect alleged whistleblowers employed by privately-owned employers even though the employer contracts with a publicly-traded company covered by SOX. Plaintiff worked for a private company that provided management services to the Fidelity family of mutual funds. She was allegedly constructively discharged after making complaints about accounting practices. In dismissing the suit, the court held that SOX does not cover contractors of a SOX-covered entity.