Cook, R. Christopher

Current Employment Position(s)

Partner

Lawyer Overview

Chris Cook has 20 years of experience as a trial lawyer in civil litigation and white-collar defense. His practice is focused on the Foreign Corrupt Practices Act (FCPA) and health care litigation, but also involves other litigation between private parties and against the government.

As a former federal prosecutor, Chris has the experience to take cases to trial.  He regularly defends clients being investigated by the Department of Justice, the Securities and Exchange Commission, and state attorneys general. His civil litigation work includes commercial disputes, class actions, False Claims Act enforcement actions, and nationwide federal cases consolidated by the Judicial Panel on Multidistrict Litigation.

Much of Chris's work relates to the FCPA, embargo violations, and other issues unique to international business. Chris has advised more than 100 clients regarding the FCPA in contexts such as responding to investigations, creating compliance policies, undertaking due diligence, negotiating business relationships, and conducting internal investigations.

Health care litigation likewise has formed a mainstay of Chris's practice since leaving the Chicago U.S. Attorney's Office in 1997. He has represented pharmaceutical companies in litigation relating to drug marketing and pricing. He also has defended health care providers under the False Claims Act, the Anti-Kickback Act, and the Stark Law. In addition, Chris represents health care clients in civil litigation between private parties.

Chris is a member of the District of Columbia Bar, the State Bar of Georgia, and the Trial Bar for the District Court for the Northern District of Illinois. In his free time, he enjoys competing in triathlons.

Areas of Practice

• Corporate Criminal Investigations
• Foreign Corrupt Practices Act and International Trade
• Health Care
• Trial Practice
• Criminal Antitrust Investigations & Litigation
• U.S. Criminal Antitrust Investigations
• Fraud & Other Business Crimes
• Government Contracts Investigations
• Health Care & Other Regulated Industries
• Internal Investigations
• Public Officials
• Securities & Accounting Fraud
• State Attorneys General Investigations & Litigation
• Corporate Compliance Programs
• e-Discovery
• Compliance Counseling & Defense
• Litigation/Health Care
• Pharmaceuticals
• Securities Litigation & SEC Enforcement
• SEC Investigations & Proceedings

Representative Cases

• Abbott and TAP Pharmaceutical defend against Average Wholesale Price (AWP) litigation , (2009)
• Aircraft manufacturer structures contractual relationship with Mideast countries in compliance with FCPA , (2009)
• Avionics service company conducts internal investigation of alleged violations of FAA regulations , (2009)
• Bon Secours settles suit challenging hospital joint venture
• Bridgestone/Firestone settles Lanham Act litigation with Goodyear over tire advertising
• Chemical manufacturer conducts internal investigation of sanctions violations and reports findings to OFAC , (2009)
• Chiropractor defends allegations of health care fraud brought by the Department of Justice
• Congressional legislative aide defends corruption investigation relating to alleged payments to a U.S. Congressman
• Consumer product company implements anti-corruption compliance program , (2009)
• Diversified multinational company conducts internal investigation to deal with antitrust allegations
• European telecommunications company seeks advice on FCPA issues in China , (2009)
• Executive of a medical device company called as a witness in FCPA investigation arising out of Eastern Europe , (2009)
• Executive of a national retailer avoids charges in DOJ investigation
• Executive of an agricultural trading company called as witness in FCPA investigation arising from sales to Thailand , (2009)
• Former government attorney avoids sanctions in accusations of violating court orders , (2009)
• Hospital health care system exonerated after DOJ investigates Medicare cost reports , (2009)
• Hospital senior executive defends allegations of paying kickbacks to physicians
• Industrial energy company conducts internal investigation of potential FCPA violations in China and creates anti-corruption compliance program , (2009)
• Industrial manufacturing company conducts FCPA internal investigation in Mexico , (2009)
• Industrial manufacturing company conducts internal investigation of potential FCPA violations in Venezuela , (2009)
• Industrial manufacturing company requests advice on FCPA compliance issues
• Industrial services company seeks advice on disclosures to the SEC and DOJ under the FCPA , (2009)
• Industrial services company seeks FCPA anti-corruption training , (2009)
• Information services company requests assistance with anti-corruption policies and procedures , (2009)
• Lafayette General Medical Center resolves False Claims Act qui tam action , (2009)
• Lobbyist/attorney testifies in corruption investigation
• Medical device manufacturer requests assistance with anti-corruption policies and procedures , (2009)
• Medical diagnostic manufacturer obtains dismissal in False Claims Act qui tam action , (2009)
• Mining company conducts due diligence and seeks advice on FCPA issues in Libya , (2009)
• Multistate hospital system conducts internal investigation , (2009)
• Oil exploration firm responds to inquiries from U.S. Congress and United Nations regarding Oil for Food Programme in Iraq , (2009)
• Oil industry services firm responds to inquiries from U.S. Congress and United Nations regarding Oil for Food Programme in Iraq , (2009)
• Pharmaceutical manufacturer defends DOJ investigation and prosecution of drug marketing and pricing practices , (2009)
• Software company requests assistance with anti-corruption policies and procedures
• SunPower acquires SunRay Renewable Energy for $277 million , (2010)
• Telecommunications company conducts internal investigation and defends DOJ investigation , (2009)
• Telecommunications company senior executive defends SEC and DOJ investigations
• U.S. manufacturing company conducts due diligence associated with purchase of a Chinese company
• U.S. security intelligence firm implements anti-corruption compliance program
• U.S. telecommunications company seeks advice on FCPA issues in China , (2009)
• Veteran's appeal to the Department of Veterans Affairs results in a rating increase to 90% overall
• Worldwide chemical manufacturer conducts internal investigation and defends DOJ antitrust investigation and litigation

West Practice Categories

Antitrust & Trade Regulation, Antitrust Law, Bankruptcy Litigation, Business & Trade, Business Organizations, Capital Markets, Class Actions, Commodities, Complex Litigation, Criminal Fraud, Criminal Law, Debarment, Defense Contracts, Disability, Elder Law, Ethics, Ethics & Professional Responsibility, Federal, Federal Appellate Practice, Federal Claims Court, Federal Contracts, Federal Trial Practice, Felonies, Food & Drug Administration, Foreign Investment, Government Construction Contracts, Government Contracts, Government Procurement, Grand Jury Proceedings, Health & Health Care Law, Hospital Law, International Law, International Trade Litigation, Litigation & Appeals, Medicare & Medicaid, Mental Health, Military & Veterans Appeals, Multidistrict Litigation, Nursing Home, Patent Litigation, Private Placements, Professional Responsibility, Public Offerings, Securities Fraud & Insider Trading, Securities Law, Securities Regulation, Social Security -- Disability, State & Municipal Contracts, State Appellate Practice, State Trial Practice, Tax Litigation, US Court of Appeals for the Federal Circuit, US Supreme Court, Victims' Rights, White Collar Crimes

Bar Admissions

• District of Columbia
• Georgia
• Illinois

Education

• Emory University
• Harvard University

Published Works

• A Fresh Look At The FCPA, The Metropolitan Corporate Counsel, 2010
• The Foreign Corrupt Practices Act: Enforcement Trends in 2010 and Beyond, 2010
• The Foreign Corrupt Practices Act: An Overview, 2010
• OECD Calls for an End to Facilitating Payments Exception, 2009
• Global Anticorruption Alert: DOJ Targets Pharmaceutical Industry and Individuals for FCPA Enforcement, 2009
• Global Anticorruption Alert: Two Los Angeles Film Executives Found Guilty of Violating the FCPA, 2009
• Fraud Enforcement Recovery Act of 2009 Becomes Law, Expanding Exposure Under the False Claims Act and Funding Anti-Fraud Enforcement, 2009
• DOJ Changes Its Rules for Assessing Corporate Cooperation, 2009
• 2009 Sunshine Act Reflects Congressional Intent to Regulate Drug, Device Industry Aggressively, 2009
• Expansive Theory of Liability for Medicare Claims Struck Down, Jones Day In Print, 2009
• Expansive theory of claims struck down, HCCA Compliance Today, 2009
• Federal Appeals Court Rejects Expansive FCA False Certification Theory and Adopts Materiality Requirement, 2008
• Legal: Foreign Policy -- Drug Companies Doing Business Abroad, Pharmaceutical Executive [link], 2007
• Will the Government Punish You For Standing By Your Employees?, 2007
• Pharma Companies Face Scrutiny Over Foreign Physician Relationships, Pharmaceutical Executive, 2006
• The Legal Obligation to Maintain Accurate Books and Records in U.S. and Non-U.S. Operations, 2006
• The Elements of an Effective Foreign Corrupt Practices Act Compliance Program, 2006
• 2006 Update on Transnational Antibribery Laws: The United States Foreign Corrupt Practices Act, International Conventions, and Recent Enforcement Actions, 2006
• Looking Beyond Arthur Andersen: The Impact on Corporate Records and Information Management Policies and Practices, The Federal Lawyer, 2005
• The Supreme Court's Decision in Arthur Andersen LLP v. United States: An Important Development Regarding the Legal Consequences of Document Retention Policies, 2005
• White Collar Defense And The Death (For Now) Of Sentencing Guidelines, The Metropolitan Corporate Counsel, 2005
• Developments in Criminal Liability and the Internet, Pike and Fischer Internet Law & Regulation, 2004

Address

51 Louisiana Avenue, N.W.
Washington, DC 20001-2113

Phones

1.202.879.3734 (Business Phone)

Faxes

1.202.626.1700 (Business Fax)

Emails

Contact Us (Business Email)

Websites

http://www.jonesday.com