Overview
Jon Lahn is a partner in the Firm’s Government, Regulatory and Internal Investigations and Litigation practice groups. Whether representing clients who are under investigation by criminal, civil or regulatory authorities, or advising companies on internal investigations and compliance issues, Jon’s practice focuses on helping companies address the complex issues that arise in highly-regulated industries. With a pragmatic approach that is tailored to the specific needs of each client, Jon helps clients efficiently resolve potential legal exposure and mitigate risk.
In the health care and life sciences industries, Jon has represented branded and generic pharmaceutical manufacturers, device manufacturers, diagnostic companies, and health care providers in dozens of federal and state investigations, including investigations relating to potential violations of the Anti-Kickback Statute, False Claims Act, and related state laws, as well in civil litigation arising out of those investigations. He also advises companies on internal investigations relating to health care compliance issues and counsels them on how best to mitigate compliance risk in the future. In addition, Jon advises companies contemplating transactions in the health care space regarding compliance risks and legal exposure.
Jon also represents U.S. and international issuers, professional service firms, and individuals in investigations and enforcement actions by the Securities & Exchange Commission and the Public Company Accounting Oversight Board. He has particular experience in SEC and PCAOB matters relating to audit quality and compliance with the Commission’s auditor independence regulations.
Jon also maintains an active pro bono practice focused on civil rights issues and is a member of Kirkland’s Firmwide Pro Bono Management Committee.
Experience
Representative Matters
Health Care and Life Sciences
- Represent pharmaceutical and device manufacturers in connection with criminal and civil investigations relating to allegations of improper remuneration to health care providers.
- Represent pharmaceutical and device manufacturers in connection with criminal and civil investigations relating to allegations of improper sales and marketing practices and off-label promotion.
- Represent device manufacturer in connection with federal criminal and civil investigations relating to product safety issues.
- Represent pharmaceutical manufacturer in connection with federal criminal and civil investigations relating to patient assistance programs and price reporting issues.
- Represented pharmaceutical manufacturer in connection with federal criminal investigation relating to misbranding violations under the Food, Drug and Cosmetic Act.
- Represent pharmaceutical manufacturer in qui tam litigation pending in federal courts in New Jersey, Illinois, Texas and California relating to allegations of improper sales and marketing practices.
- Represented pharmaceutical company in qui tam litigation in Pennsylvania relating to allegations of improper remuneration to physicians and off-label marketing.
SEC and PCAOB Enforcement Matters
- Represent U.S. and international audit firms in connection with various SEC investigations and litigation relating to alleged securities fraud and insider trading issues.
- Represent U.S. and international audit firms in connection with various PCAOB enforcement investigations.
- Represented issuer in connection with SEC investigation relating to executive compensation and disclosure issues.
- Represented international audit firm in connection with SEC enforcement investigation relating to firm’s system of quality control.
- Represented international audit firm in connection with disclosure and resolution of issues relating to violation of SEC auditor independence requirements.
- Advised international audit firm regarding potential SEC independence issues relating to government-mandated oversight roles in various foreign jurisdictions.
- Advised issuer in connection with internal investigation and resolution of Foreign Corrupt Practices Act issues.
Other Government / Regulatory Matters
- Represented hardware manufacturer in successful Department of Justice Antitrust Division leniency application involving price fixing with competitor, avoiding criminal liability and treble damages under the Sherman Act.
- Represented multiple automotive industry executives in DOJ Antitrust Division price fixing investigations.
- Represented company in connection with Department of Labor investigation relating to alleged Dodd-Frank Act whistleblower retaliation claims.
- Represented company in World Bank investigation relating to alleged improper payments to government officials in multiple countries.
Civil Litigation
- Member of trial team that obtained the largest environmental recovery in United States history—a $5.15 billion settlement from Anadarko Petroleum Company—after prevailing at trial in the U.S. Bankruptcy Court for the Southern District of New York.
Clerk & Government Experience
Law ClerkHonorable Martin C. AshmanUnited States District Court for the Northern District of Illinois2007–2009
Prior Experience
Summer Associate, Kirkland & Ellis LLP, 2006
More
Thought Leadership
Publications
Contributor, Antitrust Law Developments (Seventh), Chapter 8: Criminal Enforcement (2012)
Contributor, American Bar Association Antitrust Sentencing Guidelines Handbook (2012)
Author/Presenter, “Is the Seventh Circuit the New Third Circuit?,” Kirkland Antitrust and Competition Institute (2011)
“Writing as Remedy: The Possibilities of Court-Generated Narrative in ‘Personal Status Litigation’,” 34 Vermont Law Review 121 (2009)
“The Demise of the Law-Finding Jury and the Birth of American Legal Science,” 57 Cleveland State Law Review 553 (2009)
Note, “The Uses of History in the Supreme Court’s Takings Clause Jurisprudence,” 81 Chicago-Kent Law Review 1233 (2006)
Memberships & Affiliations
Member of the Illinois State Bar Association
Credentials
Admissions & Qualifications
- 2007Illinois
Courts
- United States District Court for the Northern District of Illinois
- United States Court of Appeals for the Seventh Circuit
- United States District Court for the Western District of New York
Languages
- Polish
Education
- Chicago-Kent College of Law at Illinois Institute of TechnologyJ.D.with High Honors2007
Order of the Coif
Chicago-Kent Law Review, Executive Notes & Comments Editor, 2006–2007
- Northwestern UniversityB.A., English2003