A recent federal court decision, Roth v. Aon Corp., Case No. 04 C 6835, 2008 U.S. Dist. LEXIS 106161 (N.D. Ill. Jan. 8, 2009) has provided a broader application of the attorney‑client privilege to communications with in‑house attorneys than have other courts. Our litigation partners James Walker and Daniel Zinman, with assistance from their colleague Hellen Park, have written a short memo examining this decision in the context of other decisions addressing similar privilege issues, and offer guidance on increasing the likelihood that communications with in‑house counsel will be protected as privileged.