If an individual told a friend that she “filed a complaint with her employer,” we doubt the friend would understand her to possibly mean that she merely voiced displeasure to a supervisor. Rather, the natural understanding of the phrase “file any complaint” requires the submission of some writing to an employer, court, or administrative body. See United States v. Bank of Farmington, 166 F.3d 853, 860 (7th Cir.1999) (“Words in a statute are to be given their plain and ordinary meaning.”) (citing United States v. James, 478 U.S. 597, 604, 106 S.Ct. 3116, 92 L.Ed.2d 483 (1986)). Other circuit courts that have tackled this issue are split. The Fourth Circuit found that verbal complaints were not protected activity in Ball v. Memphis Bar-B-Q Co., Inc., 228 F.3d 360, 364 (4th .1987) (<HOLDING>); Brennan v. Maxey’s Yamaha, 513 F.2d 179, 183
holding without discussion of the verbalwritten distinction that plaintiffs apparently oral complaints to supervisors were protected activity holding without discussion of the verbalwritten distinction that plaintiffs oral complaints were protected activity holding without discussion of the verbalwritten distinction that defendants mistaken belief that plaintiff had made apparently oral complaints to supervisors was grounds for suit holding without discussion of the verbalwritten distinction that employees voicing of concern was protected activity holding that defendant did not breach oral agreement because among other things the plaintiff had not established that the term in question was part of the oral contract