New Delhi Television Limited (NDTV) has filed a mammoth, 194 page complaint in New York State Supreme Court against principal defendants Nielsen Holdings N.V. and The Nielsen Company (together, Nielsen), Kantar Media Research PVT LTD. (Kantar), and their Indian joint venture, TAM Media Research Private Limited (TAM).  This suit appears to be the culmination of long-running efforts by plaintiff NDTV to challenge the reliability of television viewership data produced by defendant TAM.  NDTV claims that, to NDTV’s detriment, TAM’s ratings have been skewed by corruption and bribery for many years.  Although primarily a negligence and breach of contract suit, NDTV asserts one claim for “negligence per se” against Nielsen arising out of Nielsen’s alleged violation of the FCPA.  NDTV claims that many of the television stations that allegedly benefited from the corrupted ratings are owned by Indian politicians.  It claims total damages of more than $800 million.  This article summarizes the background of the dispute and NDTV’s FCPA theory of recovery, and highlights the manner in which private lawsuits may serve as de facto FCPA whistleblower complaints.