DI-DISMISSAL NUMBER OF PAGES 5 JUDGE SWANK - Order Dismissing Complaint — 2026SOX00023

UNITED STATES DEPARTMENT OF LABOR
OFFICE OF ADMINISTRATIVE LAW JUDGES
Pittsburgh, PA
Issue Date: 14 October 2026
OALJ CASE NO.: 2026-SOX-00023
OSHA CASE NO.: 301064661
In the Matter of:
MOHAMMAD ALI,
Complainant
v.
LOGITECH INTERNATIONAL SA,
Respondent
ORDER DISMISSING COMPLAINT
This matter arises under the employee protection provisions of the Sarbanes-Oxley Act of
2002, P.L. 107-204, as codified in, 18 U.S.C. § 1514A, and its implementing regulations at 29
C.F.R. Part 1980.
I. BACKGROUND
The Complainant, Mr. Mohammad Ali, filed a Complaint on October 30, 2025, alleging
retaliation in violation of SOX, stating that on or around June 30, 2025, Respondent, Logitech
International SA, terminated his employment in retaliation for raising several concerns related to
the AMECA region.
On March 18, 2026, OSHA dismissed the Complaint, stating that while Respondent is
covered under SOX because it is a subsidiary of a company within the meaning of 18 U.S.C. §
1514A, Complainant is not covered under SOX because he is not an employee within the meaning
of 18 U.S.C. § 1514A, as “[he] was an employee based in UAE, working with a foreign company,
and all alleged adverse actions occurred in a foreign country.” (Secretary’s Findings at 1) On
September 17, 2026, the undersigned issued a Notice of Assignment and Order to Show Cause
Why Complaint Should Not Be Dismissed. Complainant responded to the order on October 14,
2026.
II. DISCUSSION
It is a “longstanding principle of American law ‘that legislation of Congress, unless a
contrary intent appears, is meant to apply only within the territorial jurisdiction of the United
States.’” Morrison v. Nat'l Australia Bank Ltd., 561 U.S. 247, 255 (2010), quoting EEOC v.
Arabian American Oil Co., 499 U.S. 244, 248 (1991) (Aramco) (emphasis added). When a statute
gives no clear indication of an extraterritorial application, it has none. Id.

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The Administrative Review Board (“ARB” or “the Board”) has adopted a two-step analysis
set forth in Morrison v. Nat'l Australia Bank, Ltd. for addressing whether a law is to be applied
extraterritorially. The two-step analysis from Morrison requires the adjudicator to: (1) Consider
whether the statue reaches extraterritorially beyond the U.S., presuming that in absence of
evidence to the contrary, Congress intends legislation to apply domestically, and (2) if a statute is
not extraterritorial, consider the essential focus of the statute and where the activity occurred. Li
Tao Hu v. PTC, Inc., ARB Case No. 2017-0068, Slip op. at 4, ALJ Case No. 2017-SOX-00019
(ARB Sept. 18, 2019).
Regarding the first step, the Board held that SOX Section 806 is indeed not extraterritorial
in reach. Id.; see Garvey v. Admin. Rev. Bd., U.S. DOL, 56 F.4th 110, 123 (D.C. Cir. 2022).
Similarly, in addressing the second step, the board held that primary location of the employee’s
worksite is the key factor to consider when deciding whether a claim is a domestic or
extraterritorial application of Section 806. Hu, Slip op. at 6. If the activity occurred outside of the
U.S., then there is an impermissible extraterritorial application, and the complaint must be
dismissed. Garvey v. Morgan Stanley, ARB Case No. 2020-0034, Slip op. at 2, ALJ No. 2017-
SOX-00030 (ARB July 16, 2021), aff’d Garvey v. ARB, U.S. DOL, 56 F.4th 110, 123 (D.C. Cir.
2022).
Here, extraterritorial application of SOX Section 806 is impermissible. First, the Board
has held that SOX Section 806 is not extraterritorial in reach. Second, Complainant was an
employee based in the UAE and worked for a foreign company, ands all alleged adverse actions
occurred in a foreign country. Thus, both the first and second steps of Garvey are not satisfied.
ORDER
Accordingly, IT IS HEREBY ORDERED that the complaint in this matter is
DISMISSED.
DREW A. SWANK
Administrative Law Judge
NOTICE OF APPEAL RIGHTS: To appeal, you must file a Petition for Review ("Petition")
with the Administrative Review Board ("Board") within fourteen (14) days of the date of the
administrative law judge's decision.
Your Petition is considered filed on the date of its postmark, facsimile transmittal, or e-filing; but
if you file it in person, by hand-delivery or other means, it is filed when the Board receives

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it. See 29 C.F.R. § 1978.110(a). Your Petition must specifically identify the findings, conclusions
or orders to which you object. You may be found to have waived any objections you do not raise
specifically. See 29 C.F.R. § 1978.110(a).
At the time you file the Petition with the Board, you must serve it on all parties as well as the
Chief Administrative Law Judge, U.S. Department of Labor, Office of Administrative Law
Judges. You must also serve the Assistant Secretary, Occupational Safety and Health
Administration and, in cases in which the Assistant Secretary is a party, the Associate Solicitor,
Division of Occupational Safety and Health. See 29 C.F.R. § 1978.110(a).
If no Petition is timely filed, the administrative law judge's decision becomes the final order of
the Secretary of Labor pursuant to 29 C.F.R. §§ 1978.109(e) and 1978.110(b). Even if a Petition
is timely filed, the administrative law judge's decision becomes the final order of the Secretary of
Labor unless the Board issues an order within thirty (30) days of the date the Petition is filed
notifying the parties that it has accepted the case for review. See 29 C.F.R. § 1978.110(b).
FILING AND SERVICE OF AN APPEAL:
1. Use of EFS System: The Board’s Electronic Filing and Service (EFS) system allows
parties to initiate appeals electronically, file briefs and motions electronically, receive
electronic service of Board issuances and documents filed by other parties, and check
the status of appeals via an Internet-accessible interface. Use of the EFS system is
free of charge to all users. To file an appeal using the EFS System go to
https://efile.dol.gov. All filers are required to comply with the Board’s rules of
practice and procedure found in 29 C.F.R. Part 26, which can be accessed
at https://www.ecfr.gov/current/title-29/subtitle-A/part-26.
A. Attorneys and Lay Representatives: Use of the EFS system is mandatory for
all attorneys and lay representatives for all filings and all service related to
cases filed with the Board, absent an exemption granted in advance for good
cause shown. 29 C.F.R. § 26.3(a)(1), (2).
B. Self-Represented Parties: Use of the EFS system is strongly encouraged for all
self-represented parties with respect to all filings with the Board and service
upon all other parties. Using the EFS system provides the benefit of built-in
service on all other parties to the case. Without the use of EFS, a party is
required to not only file its documents with the Board but also to serve copies
of all filings on every other party. Using the EFS system saves litigants the
time and expense of the required service step in the process, as the system
completes all required service automatically. Upon a party’s proper use of the
EFS system, no duplicate paper or fax filings are required.
Self-represented parties who choose not to use the EFS system must file by
mail or by personal or commercial delivery all pleadings, including briefs,
appendices, motions, and other supporting documentation, directed to:

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Administrative Review Board
Clerk of the Appellate Boards
U.S. Department of Labor
200 Constitution Avenue, N.W., Room S-5220
Washington, D.C., 20210
2. EFS Registration and Duty to Designate: E-mail Address for Service
To use the Board’s EFS system, a party must have a validated user account. To create a
validated EFS user account, a party must register and designate a valid e-mail address by
going to https://efile.dol.gov, select the button to “Create Account,” and proceed through
the registration process. If the party already has an account, they may simply use the
option to “Sign In.”
Once a valid EFS account and profile has been created, the party may file a petition for
review through the EFS system by selecting “eFile & eService with the Administrative
Review Board” from the main dashboard, and selecting the button “File a New Appeal -
ARB.” In order for any other party (other than the EFS user who filed the appeal) to
access the appeal, the party must submit an access request. To submit an access request,
parties must log into the EFSSystem, select “eFile & eService with the Administrative
Review Board,” select the button “Request Access to Appeals,” search for and select the
appeal the party is requesting access to, answer the questions as prompted, and click the
button “Submit to DOL.”
Additional information regarding registration for access to and use of the EFS system,
including for parties responding to a filed appeal, as well as step-by-step User Guides,
answers to frequently asked questions (FAQs), video tutorials and contact information for
login.gov and EFS support can be found under the “Support” tab at https://efile.dol.gov.
3. Effective Time of Filings: Any electronic filing transmitted to the Board through the
EFS e-File system or via an authorized designated e-Mail address by 11:59:59 Eastern
Time shall be deemed to be filed on the date of transmission.
4. Service of Filings:
A. Service by Parties - Service on Registered EFS Users: Service upon registered EFS
users is accomplished automatically by the EFS system. Service on Other Parties or
Participants: Service upon a party that is not a registered EFS user must be
accomplished through any other method of service authorized under applicable rule
or law.
B. Service by the Board - Registered e-filers will be e-served with Board-issued
documents via EFS; they will not be served by regular mail (unless otherwise
required by law). If a party unrepresented by counsel files their appeal by regular
mail, that party will be served with Board-issued documents by regular mail. Any
party may opt into e-service at any time by registering for an EFS account as directed
above, even if they initially filed their appeal by regular mail or delivery.

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4. Proof of Service: Every party is required to prepare and file a certificate of service with
all filings. The certificate of service must identify what was served, upon whom, and
manner of service. Although electronic filing of any document through the EFS system
will constitute service of that document on all EFS-registered parties, electronic filing of
a certificate of service through the EFS system is still required. Non EFS-registered
parties must be served using other means authorized by law or rule.
5. Inquiries and Correspondence: After an appeal is filed, all inquiries and
correspondence related to filings should be directed to the Office of the Clerk of the
Appellate Boards by telephone at 202-693-6300 or by fax at 202-513-6832. Other
inquiries or questions may be directed to the Board at (202) 693-6200 or ARB-
Correspondence@dol.gov.