The Sixth Circuit has rejected the requirement that an employee’s communications “definitively and specifically” relate to a category of fraud or securities violations under the Sarbanes-Oxley Act in order to constitute protected conduct.  Rhinehimer v. U.S. Bancorp Investments, Inc., 787 F.3d 797 (6th Cir. 2015) (No. 13-6641).  In doing so, the court affirmed the district court judgment that the plaintiff had engaged in activity protected under the Sarbanes-Oxley Act when he emailed his superior alerting him to unsuitable and fraudulent trades made by a coworker, as a result of which plaintiff was terminated.  According to the Sixth Circuit, the text of the Sarbanes-Oxley Act “does not suggest any heightened showing of a factual basis for suspected fraud. . . . The well-established intent of Congress supports a broad reading of the statute’s protections.”  Thus, “an interpretation [of the statute] demanding a rigidly segmented factual showing justifying the employee’s suspicion …conflicts with the statutory design, which turns on employees’ reasonable belief rather than requiring them to ultimately substantiate their allegations.”