Lessons Learned from the Parker Drilling DPA and Ralph Lauren NPA
The latest from Fed Chair Powell and Treasury Secretary Mnuchin’s first of several days on the Hill, including their take that the economy is improving but that continued fiscal support—from the Fed and from Congress—was...more
A decision earlier this month out of the Northern District of Illinois provides important cautionary tales for companies sending marketing text messages, as well as text messaging platform providers. Defendants Ralph Lauren...more
In this EUTM case the General Court (GC) decided for The Polo/Lauren Company LP, concluding that alleged weak distinctive character of the earlier mark in regard to certain goods was amply compensated by the enhanced...more
In the latest episode of a 30-year dispute over the use of marks depicting mounted polo players, the U.S. Court of Appeals for the Second Circuit vacated the district court’s order finding contempt of a 2012 injunction. U.S....more
The Second Circuit recently vacated a contempt order entered against the U.S. Polo Association for selling sunglasses with its logo depicting two mounted polo players vying for a ball. The Second Circuit found that the...more
In the last few years, several Latin American countries and the United States have increased their focus on anti-corruption matters. This article will survey some of the most significant recent public anti-corruption...more
In early September, a New York district court granted defendants United States Polo Association, Inc. (“USPA”) and Arvind Ltd.’s (“Arvind”) motion to compel arbitration. It further dismissed Ralph Lauren Corporation and its...more
In my final post of 2013, I reviewed all of the individual Foreign Corrupt Practices Act enforcement actions which occurred in the past year. In this first post of 2014, I review all the corporate enforcement actions in 2013....more
The goal of any company regarding its compliance regime should be to make compliance a part of the fabric of your company and the face that you present to the world. That was the message from the interview conducted by Adam...more
Last week I used the 150th anniversary of the Battle of Gettysburg as a prism to look at present day compliance issues. Today I want to go in a different direction to introduce today’s topic....more
Trying to avoid the unusually strict import controls in Argentina and facilitate faster clearance of its products through customs, a subsidiary of Ralph Lauren Corp. was found to have bribed local officials between 2005 and...more
The FCPA Paparazzi has been at it again – it is fascinating to watch the reaction of practitioners and commentators in the FCPA arena. ...more
We recently caught up with Jim Meyers, partner in Orrick Herrington & Sutcliffe's Washington, D.C., office for his perspective on what we might see regarding SEC enforcement actions in the months ahead. A member of Orrick's...more
Last week, a subsidiary of American fashion designer Ralph Lauren Corporation made global news for violations of The Foreign Corrupt Practices Act of 1977 ("FCPA"). In short, FCPA prohibits covered entities – i.e., those that...more
On April 22, the U.S. Securities and Exchange Commission (SEC) announced its first non-prosecution agreement (NPA) with a company in a matter involving alleged violations of the U.S. Foreign Corrupt Practices Act (FCPA). The...more
In the two most recent corporate Foreign Corrupt Practices Act (FCPA) enforcement actions, the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) to communicate not only what they believe constitutes a...more
For the first time, the SEC has entered into a Non-Prosecution Agreement (NPA) with a company relating to misconduct under the Foreign Corrupt Practices Act (FCPA). The SEC decided not to prosecute Ralph Lauren Corporation...more
Often, enforcement officials at the SEC and the Justice Department express their wish that securities law violators own up to their (mis)conduct as soon it comes to light. That is, come to the government and explain what has...more