DC Circuit: FTC v. Boehringer Ingelheim Pharmace

Communication of business facts between employees and in-house counsel are subject to privilege where a significant provision of the communication is to obtain or provide legal advice; underlying data, however, is not protected with the communications.

https://www.cadc.uscourts.gov/internet/opinions.nsf/A81BAEEA3D756416852582B100518ADF/$file/16-5356.pdf