Partner

Arun G. Rao

Litigation & Dispute Resolution, Global Investigations & White Collar Defense

Overview

Arun G. Rao, who has held a series of distinguished government positions, will help clients navigate cutting-edge government investigations and criminal and civil enforcement actions, including fraud and consumer protection matters involving the DOJ, Federal Trade Commission, US Food and Drug Administration, US Consumer Product Safety Commission, US Department of Transportation, and other agencies, as well as high-stakes white collar work. He most recently served as a Deputy Assistant Attorney General in the US Department of Justice, where he oversaw the agency’s Consumer Protection Branch.

Arun previously served in the White House Counsel’s Office and as an Assistant US Attorney and Chief of the Southern Division of the US Attorney’s Office for the District of Maryland, where he both supervised and directly handled federal criminal cases involving public corruption, fraud and financial crimes, and national security. He also previously served as the President of Investigative Group International (IGI), where he directed many sensitive and complex investigations and provided crisis management services. He brings more than 20 years of experience litigating and investigating complex criminal and civil matters involving the world’s leading financial services, technology, pharmaceutical, healthcare, and consumer products companies, as well as universities and elected officials and candidates for office.

As the senior official responsible for overseeing DOJ’s Consumer Protection Branch, which brings criminal and civil enforcement actions relating to Americans’ health, economic security, and data privacy, Arun led a period of rapid expansion and aggressive activity. He oversaw multiple multimillion-dollar civil penalty matters concerning user privacy under the Children’s Online Privacy Protection Act (COPPA) and the Federal Trade Commission Act. He also supervised the Department of Justice team assisting the Department of Transportation’s investigation into a major airline, which resulted in a multimillion-dollar civil penalty for violations of consumer protection laws. In addition, he oversaw the first-ever criminal prosecutions and convictions of a corporation and its executives for failure to report under the Consumer Products Safety Act. Arun also testified before Congress on DOJ enforcement efforts and served on the Deputy Attorney General's Corporate Crime Advisory Group and the Emerging Technology Board, which is responsible for coordination of artificial intelligence issues.

Prior to joining DOJ, Arun served as an Assistant District Attorney in the New York County District Attorney's Office. He also clerked for the Hon. Julia Smith Gibbons (USCA 6th Cir.) and worked in the litigation department of another prominent law firm.

Experience

United States Department of Justice

United States v. TikTok, et al. (C.D. Cal. 2024) – Supervised filing of civil complaint alleging violations of COPPA and its implementing regulations in connection with the popular TikTok app.
United States v. Norfolk Southern, et al. (D. D.C. 2024) – Supervised filing of civil complaint alleging that Norfolk Southern delays passenger trains in violation of federal law.
eBay Inc. (2024) – Led negotiations resulting in agreement by eBay to pay $59 million and enhance its compliance program to resolve allegations that it violated Controlled Substances Act in connection with sale of thousands of pill presses through its website.
United States v. Family Dollar Stores LLC (E.D. Ark. 2024)– Supervised investigation leading to corporate guilty plea and $41.675 million monetary criminal penalty (largest-ever in food safety case), related to holding consumer products in insanitary conditions.
United States v. Abbott Laboratories, et al. (W.D. Mich. 2022) – Supervised negotiations culminating in order designed to ensure safe resumption of infant formula manufacturing following product recall.
United States v. AmerisourceBergen, et al. (E.D. Pa. 2022)—Supervised filing of civil complaint alleging failure to report suspicious orders of controlled substances, in violation of Controlled Substances Act.
United States v. Twitter (N.D. Cal. 2022) – Coordinated $150 million settlement of alleged FTC order violations related to acquisition and use of consumer data (as well as subsequent litigation in which X Corp., successor to Twitter, unsuccessfully sought to terminate, modify, or stay enforcement of order)
United States v. Amazon.com, Inc., et al. (W.D. Wash. 2023) – Supervised negotiation of settlement to resolve alleged violations of COPPA Act, COPPA Rule, and FTC Act related to Amazon’s voice assistant service Alexa, including permanent injunction and $25 million civil penalty.
United States v. Facebook (D. D.C. 2023) – Supervised defensive litigation in which Meta sought to prevent FTC from reopening its administrative proceeding to modify 2020 administrative order.
United States v. Gree Zhuhai, et al. (C.D. Cal. 2021) – Oversaw criminal prosecutions of global appliance company and two subsidiaries for willfully failing to report defective products, in first corporate criminal enforcement action under CPSA.
United States v. Chu, et al. (C.D. Cal. 2023) – Supervised trial team that successfully convicted two corporate executives of conspiracy to defraud CPSC and failure to furnish information under CPSA.

ENDS Litigation (multiple districts and circuits) – With the Department of Justice's Civil Appellate, oversaw defense of FDA’s denial of premarket tobacco product applications for electronic nicotine delivery systems; supervised multiple civil enforcement actions to stop illegal manufacture and sale of unauthorized products.
Alliance for Hippocratic Medicine, et al. v. U.S Food & Drug Administration, et al. (N.D. Tex. 2023) - Member of team coordinating defense of challenge to FDA’s approval of mifepristone in federal district court.

Prior Law Firm Experience

Regularly vetted candidates for executive positions and board of directors, on behalf of Ivy League and other universities, as well as leading public companies.
Directed an internal investigation into multi-million-dollar losses sustained by a fashion design company.
Provided recurring investigative services, legal counsel, and communications advice to the general counsel of an entity that owned long-term care facilities operating throughout the United States.
Managed crisis response and conducted self due diligence and opposition research for multiple prominent political candidates, elected officials, nominees, and appointees.

Represented

A witness in a criminal investigation into possible federal election law violations related to contributions made during a presidential election.
A foreign national defendant in connection with an FCPA investigation involving payment of bribes to Petrobras officials and Brazilian politicians.
Multiple individuals targeted by internet conspiracy theories, threats, and harassment.
A nonprofit organization in a federal criminal and FCA investigation involving alleged bribery and embezzlement by its former CEO.

Related Services & Industries

Services

Publications & Presentations

Education

University of Virginia, BA, with high honors
Phi Beta Kappa; Echols Scholar; President, Jefferson Literary & Debating Society; Lawn Resident; Raven Society; Tarknath Das Foundation Award; Best Honor Counsel Award
New York University School of Law, JD
Moot Court Board; Phillip C. Jessup International Law Moot Court Competition Team Award; Best Brief, Robert F. Wagner National Labor and Employment Law Moot Court Competition

Admissions

District of Columbia
New York

Courts

US Supreme Court
US Court of Appeals for the Fourth Circuit
US Court of Appeals for the Sixth Circuit
US District Court for the District of Maryland
US District Court for the Western District of Tennessee
US District Court for the Southern District of New York
US District Court for the Eastern District of New York

Professional & Community Involvement

Edward Bennett Williams Inn of Court, Washington DC, Barrister (admission by invitation), 2016 – present
Asian Pacific American Bar Association of the Greater Washington DC Area, Inc., Member of Board of Directors, 2017 – 2020
Georgetown University Law Center, Washington DC, Adjunct Professor of Law, 2017 – 2021, Courses taught: Criminal Law (Spring 2021); Externship I Seminar (Fall 2017 – Fall 2020)