This Law Firm Publication by Ogletree, Deakins, Nash, Smoak & Stewart, P.C., discusses the New Jersey Appellate Division's September 4, 2013 decision in Lippman v. Ethicon, Inc., holding that a pharmaceutical employee hired to be a watchdog can be a whistleblower under the New Jersey Conscientious Employee Protection Act (CEPA) simply by doing his job. In this decision, which departs from previous Appellate Division decisions, the court sets out a new four-part test to establish a prima facie cause of action under CEPA for "watchdog" employees.