A judge in the District Court of New Jersey recently held that voluntary cooperation with a DOJ investigation is insufficient by itself to establish personal jurisdiction over a foreign entity but can broadly waive privilege. This ruling, issued on February 1, 2022 by Judge Kevin McNulty, involves the ongoing trial of former Cognizant executives Gordon Coburn and Steven Schwartz. Coburn and Schwartz allegedly violated the Foreign Corrupt Practices Act in connection with Cognizant’s business in India, the basis of Cognizant’s settlement with the SEC and its declination with disgorgement with DOJ in 2019.