Meng-Lin Liu brought suit under the Anti-Retaliation Provision of Dodd-Frank in Liu v. Siemens A.G., No. 13-0317 (S.D.N.Y. Oct. 21. 2013). Liu, a resident of Taiwan, was Division Compliance Officer for Siemens China, a subsidiary of Siemens A.G., a German corporation. Liu raised concerns about a deal he believed circumvented internal compliance procedures put in place after Siemens pled guilty to FCPA charges. He was allegedly stripped of his duties and eventually let go. He then reported the possible FCPA violations to the SEC and brought suit under Dodd-Frank’s whistleblower protections. Under Morrison v. Nat’l Austl. Bank Ltd., 561 U.S. 247 (2010), “[w]hen a statute gives no clear indication of an extraterritorial application, it has none.” Dodd-Frank does have some extraterritorial application, but the Anti-Retaliation provision does not, reinforcing the idea that that provision is purely domestic. The Liu court held that there is no indication that Congress intended the whisteblower protections to apply extraterritorially. The case was “brought by a Taiwanese resident against a German corporation for acts concerning its Chinese subsidiary relating to alleged corruption in China and North Korea. The only connection to the United States is the fact that Siemens has [American depository receipts] that are traded on an American exchange, just as in Morrison.” The court dismissed the complaint with prejudice.