In SEC v. Straub, No. 11-9645 (S.D.N.Y. Feb. 8, 2013), the SEC alleged that executives of a Hungarian telecommunications company Magyar Telekom, Plc., had bribed Macedonian officials to limit proposed legislation that would have opened the telecommunications market in Macedonia to competition. At the time, both Magyar and its parent company, Deutsche Telekom AG, were publicly traded on U.S. stock exchanges. The SEC alleged that the defendants signed numerous management and sub-management representation letters to Magyar’s auditors falsely asserting that they had disclosed all relevant financial information and were unaware of any unlawful activity, and that this resulted in false financial statements when the Company made its annual SEC filings. The defendants were charged with violating the FCPA’s anti-bribery provision and with aiding and abetting Magyar’s violations of the FCPA’s requirement that public companies maintain accurate books and records. They moved to dismiss on multiple grounds, including, for lack of personal jurisdiction. The court rejected this argument, holding that the “minimum contacts” test for personal jurisdiction was satisfied because the defendants made false statements to the company’s foreign auditors knowing that those statements would likely affect Magyar’s financial filings in the United States.