In Cucinotta v. Deloitte & Touche, LLP, 302 P.3d 1099 (Nev. 2013) (No. 58727), the Nevada Supreme Court adopted Restatement (Second) of Torts § 592A (1977), holding that one who is required by law to publish defamatory matter is absolutely privileged to publish it when (1) the communication is made pursuant to a lawful process, and (2) the communication is made to a qualified person. Here, a Deloitte auditor for a publicly-traded gaming company (GCA) became aware of an FBI bulletin while conducting an audit of a different company. The FBI bulletin implicated the conduct of GCA and two members of its board. After confirming the validity of the document, Deloitte’s in-house counsel prepared a summary of the bulletin’s contents and provided the summary to GCA’s Audit Committee, requesting that GCA conduct an investigation. GCA delayed release of a quarterly report, and engaged outside counsel to conduct an internal investigation, which revealed no wrongdoing. Despite the findings, the price of the stock dropped and the two board members resigned. The former board members then sued Deloitte and the auditor who initially reported the FBI bulletin for defamation and tortious interference. The Nevada Supreme Court affirmed summary judgment in favor of the auditors. Here, the auditors had a legal obligation under the federal securities laws to take certain actions when they detected potential wrongdoing, and they reported the issue to qualified persons: GCA’s audit committee. Under these circumstances, Deloitte’s communications with the audit committee were absolutely privileged and could not give rise to defamation claims.