Random Thoughts – Howard@OpenAir

Howard@OpenAir

Random Thoughts

I’ve moved! Open Air Blog is now on the Svbtle platform. It’s an easy fix: just go to openairblog.com! Don’t worry, I’ll keep reminding you.

Counting to 10, Internet Fact-Checkers, and Integrating Acquisitions

I had a boss at the SEC that used to make us read and research all the boilerplate language we put in briefs. He was right, and I forgot his lesson. I spend 1,000 words setting the record straight.

“The Limit Should Be Zero Dollars”

What's the fastest way to crumble your reputation to dust? Say something like "the limit [for hospitality] should be zero dollars. That will keep you safe." No. That won't keep you safe.

He Wanted To Be Like Nolan Ryan: Roger Clemens and Why I Left Litigation

I don’t know if Roger Clemens is innocent. I took some time from my enjoyment of Compliance Week to go watch the Roger Clemens trial. I haven’t sat in a Courtroom and watched proceedings for a while; a long while. In fact, I think the last time I sat in a Courtroom at all was […]

Time Out For a Little Technology

Time for a little off-topic technology for you. My friend and colleague Tom Fox always tells me that I need to write this post: what iPad apps I find useful. I’m a voracious user of the iPad. In fact, I’m traveling on business right now, and didn’t even bring my laptop, I find the iPad […]

Defending Wal-Mart

I’m thinking that if I wanted to cement my standing as the reigning anti-corruption iconoclast, a headline like this one would do it. In the face of the indefensible, let me offer a defense. Or, at least, some mitigating facts which you should take into account. The overriding thing I thought of when I read […]

Letter from the DOJ to the 5th Circuit

Yes, Marbury v. Madison is still the law of the land. And unlike the FCPA Blog’s Dick Cassin, the first time I read the case, I got one thing wrong: who won. No kidding. But I have to say that as I read the letter and having listened to the recording of the argument, and […]

You’re Hired. Now What?

One of the pieces of advice I regularly give to compliance people wanting to know “where do I start?” is to pick a place and start. The act of starting brings its own momentum. And there’ll be enough to do that you can start anywhere. Like in military parlance, any action is better than none. […]

Off Topic: Cursing in Court

One of the many fond memories I have of being an Assistant DA is cursing in Court. I’m thinking about this because I just saw an article about a CNN reporter who used a racial slur on air (sort of). Let me say at the outset that I’ve never been held in contempt (once, though, […]

Prosecutorial Fatalism: An Open Letter to Lanny Breuer and Chuck Duross

Dear Lanny (or, as I like to call you, Mr. Assistant Attorney General, sir) & Chuck, Like any member of the public, I’ve been discouraged and disappointed by recent headlines in the press about FCPA prosecutions. When I read things like “‘Foolish and Unprofessional’ Behavior Infected FCPA Prosecutions” in today’s FCPA Blog, or read about […]

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