A trial court granted JP Morgan summary judgment on Plaintiff’s Sarbanes-Oxley Act (SOX) complaint because she failed to show her complaint “definitively and specifically” related to one of the six categories of misconduct covered by SOX. The Second Circuit reversed, rejecting the “definitively and specifically” standard as too strict and held that a plaintiff need only show she “reasonably believed” the reported conduct amounted to a violation enumerated under SOX. Sharkey v. J.P. Morgan Chase & Co.,580 F. App’x 28 (2d Cir. 2014) (No. 13-4741). Following remand, JP Morgan filed a renewed motion for summary judgment, arguing that regardless of which standard applies, Sharkey’s claim fails under SOX. Defs.’ Mem. of Law in Supp. of Renewed Mot. for Summ. J., Sharkey v. J.P. Morgan Chase & Co., No. 10-CV-03824 (S.D.N.Y. Dec. 22, 2014), ECF No. 90. JP Morgan argues that Sharkey could not have reasonably believed the reported conduct, which related to the Patriot Act and an anti-money laundering statute, violated a statute enumerated under SOX because neither statute is explicitly enumerated under SOX.