In Huang v. Harman, Int’l Indus. Inc., 2015 U.S. Dist. LEXIS 98594 (D. Conn. July 29, 2015), the United States District Court for the District of Connecticut found that a pro se plaintiff stated a claim by attaching his OSHA complaint to his federal court complaint. In the OSHA complaint, the plaintiff sufficiently alleged that he had uncovered accounting errors, including misstated inventory reserves, sales, and gross margins, that led to an overstatement of profits of $20 million. The court found that the plaintiff’s training as an accountant and work as a SOX auditor supported plaintiff’s reasonable belief that he was engaging in SOX-protected activity. Further, the plaintiff’s supervisor had encouraged him to pursue his concerns. The court rejected the defendant’s argument that the alleged accounting errors were “innocuous or trivial” because the errors were numerous, were in different departments at different times, amounted to tens of millions of dollars, and were reported to shareholders on SEC filings.