The Federal Circuit Court of Appeals held that reliance on the advice of in-house counsel waived the attorney-client privilege as to that advice and also waived the attorney-client privilege as to advice rendered by outside counsel on the same subject matter, even though the client was not relying on the advice of that outside counsel. The Court ruled, however, that the defense did not waive the work product privilege with regard to documents prepared by outside counsel that were never transmitted to the client.