Government Investigations

Gray has represented:

  • A U.S.-based fintech company in connection with joint DOJ and FTC investigations of Payroll Protection Plan (PPP) lending practices
  • A Houston-based green energy company in connection with DOJ, NSF, and Department of Navy investigations of alleged False Claims Act violations, obtaining out of court resolution and no debarment
  • A global public technology company in connection with a DOJ/SEC investigation of alleged FCPA violations obtaining a DOJ declination letter
  • A global accounting firm in connection with an SEC investigation of potential misstatements and accounting fraud resulting in declination
  • A global life sciences company in connection with DOJ/SEC investigations of alleged FCPA violations in multiple countries resulting in no enforcement action
  • A New York Stock Exchange listed defense company in an internal investigation and self-disclosure to the Department of Justice of potential FCPA violations resulting in declination
  • A hedge fund and its investment adviser in an SEC insider trading investigation. Resolved with no enforcement action initiated
  • A public HR administrative services company executive in an SEC financial fraud investigation. Resolved with no enforcement action initiated
  • A securities broker-dealer in appeal of a securities industry bar to the DC Circuit Court of Appeals
  • An investment adviser in an SEC and DOJ Ponzi scheme investigation. US District Court for the Northern District of Illinois
  • Public technology companies and a public company officer in SEC investigations of options backdating an individual investor in an insider trading investigation

Regulatory Compliance

Gray has advised:

  • A Fortune 50 energy company in connection with a compliance risk assessment and the design and implementation of its compliance program
  • A global energy company in connection with the design and implementation of its anti-bribery program
  • An international semiconductor products manufacturer in preparation and implementation of anti-bribery policy, procedures and training program
  • A global insurance company in preparation and implementation of anti-money laundering policies, procedures and programs 

Litigation

Gray has represented:

  • A major pharmaceutical company in qui tam litigation, winning summary judgment. US District Court for the Eastern District of Pennsylvania
  •  A New York Stock Exchange listed packaged ice manufacturer in securities and shareholder derivative litigation, obtaining dismissal of the derivative action. US District Court for the Eastern District of Michigan and Dallas County District Court
  • A real estate investment firm as first-chair trial counsel in trial involving alleged breach of contract and alleged failure to satisfy multi-million dollar guaranty obligations, winning take-nothing judgment in favor of client. Harris County District Court. Successfully defended on appeal as lead appellate counsel. First Court of Appeals of Texas
  • A Chinese company listed on the New York Stock Exchange in putative class action securities litigation and shareholder derivative litigation based on alleged securities fraud in connection with a reverse merger and secondary public offering of securities in the US. US District Court for the Southern District of New York
  • A global accounting firm in putative class action securities litigation and other litigation in connection with alleged Ponzi scheme. US District Court for the Northern District of Texas
  • A global insurance company in a lawsuit filed by a large commercial bank involving an alleged half-billion dollar loss associated with investments made pursuant to a bank-owned life insurance (BOLI) policy. US District Court for the Southern District of Ohio
  • A corporate executive in contract litigation and international collection efforts by a foreign sovereign involving a personal guaranty on a multimillion-dollar bank loan, obtaining summary judgment on behalf of client. US District Court for the District of Columbia and US Court of Appeals for the District of Columbia Circuit
  • A public company in a direct shareholder suit involving acquisition of the company by a private equity firm. Maryland Circuit Court