On September 25, 2012, a federal judge in Connecticut resolved an apparent tension between the anti-retaliation provision of the Dodd-Frank Act ("Dodd-Frank" or the "Act") and the definition of "whistleblower" under that Act in a way that broadly interprets the protections afforded to employees who report issues they "reasonably believe" constitute violations of the securities laws, even where the employee has never raised the issue with the Securities and Exchange Commission ("SEC").