Earlier this month, the US Court of Appeals for the Ninth Circuit widened a growing split among federal courts over whether Dodd-Frank’s anti-retaliation protections extend to whistleblowers who voice concerns about potential securities law violations internally, but do not report those violations to the SEC. In a divided panel decision, the Ninth Circuit answered that question in the affirmative, holding that internal reporting alone is sufficient to qualify an employee for whistleblower status under Dodd-Frank. The court thus affirmed the district court’s ruling allowing the plaintiff to proceed with a Dodd-Frank retaliation claim against his former employer. The case is Somers v. Digital Realty Trust, 15-17352 (9th Cir. Mar. 8, 2017).