On June 27, 2011, the U.S. Supreme Court declined to review an appeals court decision that inhibits a multinational company’s ability to fully defend itself in civil litigation that follows a criminal investigation. The denial of review was a setback for WLF, which filed a brief in the case urging the ultimate reversal of a decision by the U.S. Court of Appeals for the Ninth Circuit. In its brief, WLF expressed serious concerns that the Ninth Circuit’s per se rule categorically disregarding a civil protective order in favor of a grand jury subpoena significantly burdens the relationship between a corporate defendant and its counsel in cases where the corporation faces parallel civil and criminal proceedings.