Partners David Simon, Michael Halfenger, Pamela Johnston, Jaime Guerrero, and Kenneth Winer and Associates James Cirincione and Lauren Valiente submitted a brief in the appellate court case of United States of America v. Rodríguez. Filed on behalf of the defendant-appellant, Carlos Rodriguez, the brief questions the District Court's interpretation of the term “foreign official” under the Foreign Corrupt Practices Act (FPCA), and represents the first time in FCPA history that the term has been disputed in appellate court.