A Fond Farewell to Two of the Commercial Division’s Most Senior Judges

by Patterson Belknap Webb & Tyler LLP

The arrival of the new year is a bittersweet time for the Commercial Division as it bids farewell to two of its most senior judges: Justice Charles E. Ramos and Justice Eileen Bransten.  Notably, both will be staying on to serve the Court as Judicial Hearing Officers.

Both Justice Ramos and Justice Bransten had illustrious judicial careers that began similarly.  After graduating from Fordham Law School, they both spent time in private practice before pursuing judicial careers first as Civil Court Judges.  Thereafter, both were elected to the Supreme Court and then assigned to the Commercial Division.

Together their combined service on the Commercial Division bench exceeds 30 years.  During that time, they wrestled with complex legal issues and issued innovative decisions that helped shape New York commercial law.  They also both contributed significantly to the way in which practice is handled in the Division, including through their service on the Commercial Division Advisory Council.  Below are short biographies with a sampling of a few of their decisions.[1]

Justice Charles E. Ramos served as a New York County Commercial Division Justice since 1996 and—before his retirement from the bench—was the Division’s Senior Justice.  In 2013, Justice Ramos was designated as the Justice to handle all international arbitration cases filed in the New York County Commercial Division.  In 2018, the New York State Bar Association conferred the Hon. Stanley H. Fuld Award upon him for his contributions to commercial law. 

No Oral Modification Clause

In Obsessive v. Sephora,[2] Justice Ramos denied the defendant’s motion to dismiss breach of contract and promissory estoppel claims.  Even though the written contract contained a no oral modification clause, Justice Ramos ruled that an exception to the terms of that clause existed.  Justice Ramos explained that an oral modification may be enforced—despite a no oral modification clause—when partial or complete performance of the oral modification has occurred and that performance is “unequivocally referable to the oral modification” and not contemplated in the original agreement.[3]

Despite the clause barring oral modifications, Justice Ramos held that both oral modifications were enforceable because the plaintiff had unequivocally performed[4] and the performance was not covered by the written agreement.[5]


In confirming an arbitration award in NSB v. C.L. King, Justice Ramos explained that New York gives “extreme deference to arbitrators.”[6]  Therefore, to vacate an arbitration award on the basis of a claimed manifest disregard of the law, “a court must find that (1) the arbitration panel knew of a governing law yet refused to apply it or ignored it, and (2) the governing law was well defined, explicit, and clearly applicable.”[7]  Justice Ramos further explained that the manifest disregard doctrine is “severely limited” and that courts will enforce an arbitration award so long as it offers a “barely colorable justification for the outcome reached.”[8]

Justice Ramos confirmed the arbitration award, finding the record to be lacking because the defendant failed to “provide a complete record of the Arbitration[]” and the parties had failed to request a written explanation for the arbitration award, as they were entitled to.[9]  Given that the award did not explain how the Panel reached its decision, Justice Ramos ruled that the defendant had presented “mere conjecture” regarding the Panel’s decision and “[s]uch speculation is inconclusive and fails to show that the Panel lacked colorable justification for its decision.”[10]  Therefore, Justice Ramos denied the defendant’s cross-motion to vacate the arbitration award. 

Employer’s Computer Use Policy

In Scott v. Beth Israel Med. Ctr.,[11] Justice Ramos denied the plaintiff-employee’s motion for a protective order seeking the return of privileged emails, ruling that the plaintiff had waived attorney-client privilege when he used a work email address to communicate with counsel.  The defendant-employer had a computer use policy providing that its system “should be used for business purpose[s] only[]” and “employees have no personal privacy right” in any materials created using the defendant’s computer system.[12]  Justice Ramos determined that the effect of such a policy “is to have the employer looking over your shoulder each time you send an e-mail.”[13]

Since there was no New York case on point, Justice Ramos looked for guidance to a federal bankruptcy case, which was “virtually identical.”[14]  Accordingly, Justice Ramos adopted the Asia Global court’s four factor test to determine if the employee had waived attorney-client privilege by using his work email to communicate with counsel: “‘(1) . . . the corporation maintain[s] a policy banning personal or other objectionable use, (2) . . . the company monitor[s] the use of the employee's computer or e-mail, (3) . . . third parties have a right of access to the computer or e-mails, and (4) . . . the corporation notif[ies] the employee, or was the employee aware, of the use and monitoring policies?’”[15]

Justice Ramos found that the Asia Global factors weighed in favor of the plaintiff having waived the privilege, holding that the plaintiff had both actual and constructive notice of the defendant’s policy to regulate and monitor the use of its computer system.[16]

Justice Eileen Bransten was elected to the Supreme Court in 1999 and assigned to the New York County Commercial Division in 2008.  In 2013, Chief Judge Jonathan Lippman appointed her to serve on the Commercial Division Advisory Council.  She was formerly President of the Association of Supreme Court Justices of the State of New York.

Personal Jurisdiction Based on an Alter Ego Theory

In Gowen v. Helly Nahmad Gallery,[17] Justice Bransten held that the Court acquired personal jurisdiction over a non-domiciliary defendant based on an alter ego theory.  The case involved a painting that the Nazis had allegedly seized.  Justice Bransten ruled that the Court had personal jurisdiction over the defendant-corporation under CPLR 302(a)(1) (transacting business in the State) and 302(a)(2) (committing a tortious act in the State).  Justice Bransten then determined that the court also acquired personal jurisdiction over the individual defendant based on an alter ego theory.  The Court reasoned that “by and through his conducting business vis-à-vis [his corporation] and, in so doing, so perverting its corporate form such that this court cannot determine a substantial difference between the [individual defendant and the corporation].”[18] Justice Bransten further ruled that the painting’s absence from the State of New York was of no consequence because it is an “overarching principle of New York law” that “one party cannot hide its assets outside of New York” to render the New York judgment unenforceable. [19]

Plaintiffs typically use alter ego theories to establish a party’s liability.  However, Justice Bransten’s decision in Gowen demonstrates that an alter ego theory can also be used to establish personal jurisdiction. 

Partnership Deadlock

In what appears to be an issue of first impression, in Magid v. Magid, Justice Bransten ruled that when seeking judicial dissolution under N.Y. Partnership Law § 63, a 50/50 divide among the partners is not necessary in order for the Court to find that a “partnership is irretrievably deadlocked.”[20] Justice Bransten denied both parties’ summary judgment motions, ruling that there was an issue of fact as to the level of dysfunction among the partners.[21]

Long-Arm Jurisdiction

In Ace Decade Holdings v. UBS,[22] Justice Bransten dismissed a fraud suit involving non- domiciliary parties due to lack of personal jurisdiction and inconvenient forum.  Justice Bransten found no basis to exercise jurisdiction over a foreign defendant “with respect to claims arising out of an entirely foreign transaction.”[23]

In a post-Daimler world, Justice Bransten explained that “New York courts have recognized that ‘doing business’ in New York is no longer a constitutionally sufficient basis for the exercise of general jurisdiction over foreign entities[,]” and therefore, the defendant’s contacts with New York are not sufficient to “render it essentially at home” in New York.[24]

Having found no basis for general jurisdiction, Justice Bransten held that the “Plaintiff has failed to establish that long-arm jurisdiction may be exercised under any subsection of CPLR § 302(a).”[25]  Notably, Justice Bransten rejected the plaintiff’s argument that its move to New York— after entering into the relevant agreements—was sufficient to establish jurisdiction, finding that the plaintiff “cannot manufacture jurisdiction over [the defendant] by moving its operations to New York[]” since none of the defendant’s alleged acts “were performed in New York.” [26]

Justice Bransten further held that, even if jurisdiction could be established, dismissal of the case was also warranted based on the doctrine of forum non conveniens.  The Court reasoned that the claim lacked a “substantial nexus with New York” and nearly “all relevant documents and all witnesses” were located outside of New York.[27]

*          *          *

These two standouts of the Commercial Division and their years of experience will be sorely missed.  As of January 1, 2019, their posts have been filled by Hon. Joel M. Cohen and Hon. Andrew S. Borrok.

[1] Both have also been involved with RMBS litigations but those cases will not be covered here. 

[2] Obsessive Compulsive Cosmetics, Inc. v. Sephora USA, Inc., 2016 BL 307244 (Sup. Ct. 2016).

[3] Id. at *2 (quoting Rose v Spa Realty Associates, 42 N.Y.2d 338, 341, 397 N.Y.S.2d 922, 924 (1977)).

[4] Oral modification 1: Defendant verbally agreed to become the exclusive non-online purchaser of plaintiff’s products, a condition not covered in the written agreement.  Plaintiff unequivocally performed by refusing to sell its products to other stores.  Id. at *1.

Oral modification 2: To induce the plaintiff to place it products in twenty-six of its locations, the defendant verbally agreed to share the fixture costs 50/50 with the plaintiff.  Id.  The written agreement was not a requirements contract, and the plaintiff initially refused the defendant’s purchase orders because the fixture costs would be too great. Id. at *3.  After the oral agreement, the plaintiff unequivocally performed by producing new products to fill the defendant’s purchase orders, but when the plaintiff insisted that the defendant share the fixture costs, the defendant cancelled its purchase orders.  Id. at *1.

[5] In the written agreement, the plaintiff agreed to sell its product to the defendant and the plaintiff was responsible for covering certain expenses, such as fixture costs.  Id.

[6] NSB Advisors, LLC v. C.L. King & Associates, Inc., No. 657034/2017, 2018 BL 388363, at *3 (Sup. Ct. 2018).

[7] Id. at *3.

[8] Id. (internal quotations omitted).

[9] Id. at *4.


[11] Scott v. Beth Israel Med. Ctr. Inc., 847 N.Y.S.2d 436 (Sup. Ct. 2007).

[12] Id. at 439.

[13] Id. at 440.

[14] Id. at 441.

[15] Id. at 442 (quoting In re Asia Global Crossing, Ltd., 322 BR 247, 257 (S.D.N.Y. 2005)).

[16] Id. at 442 – 43.

[17] Gowen v. Helly Nahmad Gallery, Inc., No. 650646/2014, 2018 BL 164601 (Sup. Ct. 2018).

[18] Id. at *7.

[19] Id. at *9 – 10.

[20] Magid v Magid, 2017 NY Slip Op 32603(U), at *5 (Sup. Ct. 2017).

[21] Shortly thereafter, the parties resolved the dispute and entered into a stipulation of discontinuance.  See NYSCEF Doc. No. 175.

[22] Ace Decade Holdings Ltd. v. UBS AG, No. 653316/2015, 2016 BL 413780 (Sup. Ct. 2016).

[23] Id. at *8.

[24] Id. at *5.

[25] Id. at *11.  Under 302(a)(1), Justice Bransten ruled that based on the totality of the circumstances, the claim did not arise out of business transacted in NY.  Id. at *8.  Under 302(a)(2),  she found that defendant did not commit a tortious act within the State.  The record was not clear whether plaintiff alleged the defendant made ongoing misrepresentations once the plaintiff moved to NY.  In any event, Justice Bransten found that the misrepresentations alone would not be sufficient to exercise jurisdiction.  Id. at *8.  And under 302(a)(3), Justice Bransten held that the defendant did not cause injury in NY because the money used for the investment was never held in a NY account, and further, the plaintiff’s residency in NY alone is not sufficient to establish jurisdiction.  Id. at *10 – 11.

[26] Id. at *7 – 8.

[27] Id. at *11 – 12.


DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Patterson Belknap Webb & Tyler LLP | Attorney Advertising

Written by:

Patterson Belknap Webb & Tyler LLP

Patterson Belknap Webb & Tyler LLP on:

Readers' Choice 2017
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide

JD Supra Privacy Policy

Updated: May 25, 2018:

JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.

This Privacy Policy describes how JD Supra, LLC ("JD Supra" or "we," "us," or "our") collects, uses and shares personal data collected from visitors to our website (located at www.jdsupra.com) (our "Website") who view only publicly-available content as well as subscribers to our services (such as our email digests or author tools)(our "Services"). By using our Website and registering for one of our Services, you are agreeing to the terms of this Privacy Policy.

Please note that if you subscribe to one of our Services, you can make choices about how we collect, use and share your information through our Privacy Center under the "My Account" dashboard (available if you are logged into your JD Supra account).

Collection of Information

Registration Information. When you register with JD Supra for our Website and Services, either as an author or as a subscriber, you will be asked to provide identifying information to create your JD Supra account ("Registration Data"), such as your:

  • Email
  • First Name
  • Last Name
  • Company Name
  • Company Industry
  • Title
  • Country

Other Information: We also collect other information you may voluntarily provide. This may include content you provide for publication. We may also receive your communications with others through our Website and Services (such as contacting an author through our Website) or communications directly with us (such as through email, feedback or other forms or social media). If you are a subscribed user, we will also collect your user preferences, such as the types of articles you would like to read.

Information from third parties (such as, from your employer or LinkedIn): We may also receive information about you from third party sources. For example, your employer may provide your information to us, such as in connection with an article submitted by your employer for publication. If you choose to use LinkedIn to subscribe to our Website and Services, we also collect information related to your LinkedIn account and profile.

Your interactions with our Website and Services: As is true of most websites, we gather certain information automatically. This information includes IP addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data. We use this information to analyze trends, to administer the Website and our Services, to improve the content and performance of our Website and Services, and to track users' movements around the site. We may also link this automatically-collected data to personal information, for example, to inform authors about who has read their articles. Some of this data is collected through information sent by your web browser. We also use cookies and other tracking technologies to collect this information. To learn more about cookies and other tracking technologies that JD Supra may use on our Website and Services please see our "Cookies Guide" page.

How do we use this information?

We use the information and data we collect principally in order to provide our Website and Services. More specifically, we may use your personal information to:

  • Operate our Website and Services and publish content;
  • Distribute content to you in accordance with your preferences as well as to provide other notifications to you (for example, updates about our policies and terms);
  • Measure readership and usage of the Website and Services;
  • Communicate with you regarding your questions and requests;
  • Authenticate users and to provide for the safety and security of our Website and Services;
  • Conduct research and similar activities to improve our Website and Services; and
  • Comply with our legal and regulatory responsibilities and to enforce our rights.

How is your information shared?

  • Content and other public information (such as an author profile) is shared on our Website and Services, including via email digests and social media feeds, and is accessible to the general public.
  • If you choose to use our Website and Services to communicate directly with a company or individual, such communication may be shared accordingly.
  • Readership information is provided to publishing law firms and authors of content to give them insight into their readership and to help them to improve their content.
  • Our Website may offer you the opportunity to share information through our Website, such as through Facebook's "Like" or Twitter's "Tweet" button. We offer this functionality to help generate interest in our Website and content and to permit you to recommend content to your contacts. You should be aware that sharing through such functionality may result in information being collected by the applicable social media network and possibly being made publicly available (for example, through a search engine). Any such information collection would be subject to such third party social media network's privacy policy.
  • Your information may also be shared to parties who support our business, such as professional advisors as well as web-hosting providers, analytics providers and other information technology providers.
  • Any court, governmental authority, law enforcement agency or other third party where we believe disclosure is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights, the rights of any third party or individuals' personal safety, or to detect, prevent, or otherwise address fraud, security or safety issues.
  • To our affiliated entities and in connection with the sale, assignment or other transfer of our company or our business.

How We Protect Your Information

JD Supra takes reasonable and appropriate precautions to insure that user information is protected from loss, misuse and unauthorized access, disclosure, alteration and destruction. We restrict access to user information to those individuals who reasonably need access to perform their job functions, such as our third party email service, customer service personnel and technical staff. You should keep in mind that no Internet transmission is ever 100% secure or error-free. Where you use log-in credentials (usernames, passwords) on our Website, please remember that it is your responsibility to safeguard them. If you believe that your log-in credentials have been compromised, please contact us at privacy@jdsupra.com.

Children's Information

Our Website and Services are not directed at children under the age of 16 and we do not knowingly collect personal information from children under the age of 16 through our Website and/or Services. If you have reason to believe that a child under the age of 16 has provided personal information to us, please contact us, and we will endeavor to delete that information from our databases.

Links to Other Websites

Our Website and Services may contain links to other websites. The operators of such other websites may collect information about you, including through cookies or other technologies. If you are using our Website or Services and click a link to another site, you will leave our Website and this Policy will not apply to your use of and activity on those other sites. We encourage you to read the legal notices posted on those sites, including their privacy policies. We are not responsible for the data collection and use practices of such other sites. This Policy applies solely to the information collected in connection with your use of our Website and Services and does not apply to any practices conducted offline or in connection with any other websites.

Information for EU and Swiss Residents

JD Supra's principal place of business is in the United States. By subscribing to our website, you expressly consent to your information being processed in the United States.

  • Our Legal Basis for Processing: Generally, we rely on our legitimate interests in order to process your personal information. For example, we rely on this legal ground if we use your personal information to manage your Registration Data and administer our relationship with you; to deliver our Website and Services; understand and improve our Website and Services; report reader analytics to our authors; to personalize your experience on our Website and Services; and where necessary to protect or defend our or another's rights or property, or to detect, prevent, or otherwise address fraud, security, safety or privacy issues. Please see Article 6(1)(f) of the E.U. General Data Protection Regulation ("GDPR") In addition, there may be other situations where other grounds for processing may exist, such as where processing is a result of legal requirements (GDPR Article 6(1)(c)) or for reasons of public interest (GDPR Article 6(1)(e)). Please see the "Your Rights" section of this Privacy Policy immediately below for more information about how you may request that we limit or refrain from processing your personal information.
  • Your Rights
    • Right of Access/Portability: You can ask to review details about the information we hold about you and how that information has been used and disclosed. Note that we may request to verify your identification before fulfilling your request. You can also request that your personal information is provided to you in a commonly used electronic format so that you can share it with other organizations.
    • Right to Correct Information: You may ask that we make corrections to any information we hold, if you believe such correction to be necessary.
    • Right to Restrict Our Processing or Erasure of Information: You also have the right in certain circumstances to ask us to restrict processing of your personal information or to erase your personal information. Where you have consented to our use of your personal information, you can withdraw your consent at any time.

You can make a request to exercise any of these rights by emailing us at privacy@jdsupra.com or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

You can also manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard.

We will make all practical efforts to respect your wishes. There may be times, however, where we are not able to fulfill your request, for example, if applicable law prohibits our compliance. Please note that JD Supra does not use "automatic decision making" or "profiling" as those terms are defined in the GDPR.

  • Timeframe for retaining your personal information: We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, or subsequently authorized. We may continue processing your personal information for longer periods, but only for the time and to the extent such processing reasonably serves the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research and statistical analysis, and subject to the protection of this Privacy Policy. For example, if you are an author, your personal information may continue to be published in connection with your article indefinitely. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
  • Onward Transfer to Third Parties: As noted in the "How We Share Your Data" Section above, JD Supra may share your information with third parties. When JD Supra discloses your personal information to third parties, we have ensured that such third parties have either certified under the EU-U.S. or Swiss Privacy Shield Framework and will process all personal data received from EU member states/Switzerland in reliance on the applicable Privacy Shield Framework or that they have been subjected to strict contractual provisions in their contract with us to guarantee an adequate level of data protection for your data.

California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, our customers who are California residents have the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

You can make a request for this information by emailing us at privacy@jdsupra.com or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

Some browsers have incorporated a Do Not Track (DNT) feature. These features, when turned on, send a signal that you prefer that the website you are visiting not collect and use data regarding your online searching and browsing activities. As there is not yet a common understanding on how to interpret the DNT signal, we currently do not respond to DNT signals on our site.

Access/Correct/Update/Delete Personal Information

For non-EU/Swiss residents, if you would like to know what personal information we have about you, you can send an e-mail to privacy@jdsupra.com. We will be in contact with you (by mail or otherwise) to verify your identity and provide you the information you request. We will respond within 30 days to your request for access to your personal information. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. If you would like to correct or update your personal information, you can manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard. If you would like to delete your account or remove your information from our Website and Services, send an e-mail to privacy@jdsupra.com.

Changes in Our Privacy Policy

We reserve the right to change this Privacy Policy at any time. Please refer to the date at the top of this page to determine when this Policy was last revised. Any changes to our Privacy Policy will become effective upon posting of the revised policy on the Website. By continuing to use our Website and Services following such changes, you will be deemed to have agreed to such changes.

Contacting JD Supra

If you have any questions about this Privacy Policy, the practices of this site, your dealings with our Website or Services, or if you would like to change any of the information you have provided to us, please contact us at: privacy@jdsupra.com.

JD Supra Cookie Guide

As with many websites, JD Supra's website (located at www.jdsupra.com) (our "Website") and our services (such as our email article digests)(our "Services") use a standard technology called a "cookie" and other similar technologies (such as, pixels and web beacons), which are small data files that are transferred to your computer when you use our Website and Services. These technologies automatically identify your browser whenever you interact with our Website and Services.

How We Use Cookies and Other Tracking Technologies

We use cookies and other tracking technologies to:

  1. Improve the user experience on our Website and Services;
  2. Store the authorization token that users receive when they login to the private areas of our Website. This token is specific to a user's login session and requires a valid username and password to obtain. It is required to access the user's profile information, subscriptions, and analytics;
  3. Track anonymous site usage; and
  4. Permit connectivity with social media networks to permit content sharing.

There are different types of cookies and other technologies used our Website, notably:

  • "Session cookies" - These cookies only last as long as your online session, and disappear from your computer or device when you close your browser (like Internet Explorer, Google Chrome or Safari).
  • "Persistent cookies" - These cookies stay on your computer or device after your browser has been closed and last for a time specified in the cookie. We use persistent cookies when we need to know who you are for more than one browsing session. For example, we use them to remember your preferences for the next time you visit.
  • "Web Beacons/Pixels" - Some of our web pages and emails may also contain small electronic images known as web beacons, clear GIFs or single-pixel GIFs. These images are placed on a web page or email and typically work in conjunction with cookies to collect data. We use these images to identify our users and user behavior, such as counting the number of users who have visited a web page or acted upon one of our email digests.

JD Supra Cookies. We place our own cookies on your computer to track certain information about you while you are using our Website and Services. For example, we place a session cookie on your computer each time you visit our Website. We use these cookies to allow you to log-in to your subscriber account. In addition, through these cookies we are able to collect information about how you use the Website, including what browser you may be using, your IP address, and the URL address you came from upon visiting our Website and the URL you next visit (even if those URLs are not on our Website). We also utilize email web beacons to monitor whether our emails are being delivered and read. We also use these tools to help deliver reader analytics to our authors to give them insight into their readership and help them to improve their content, so that it is most useful for our users.

Analytics/Performance Cookies. JD Supra also uses the following analytic tools to help us analyze the performance of our Website and Services as well as how visitors use our Website and Services:

  • HubSpot - For more information about HubSpot cookies, please visit legal.hubspot.com/privacy-policy.
  • New Relic - For more information on New Relic cookies, please visit www.newrelic.com/privacy.
  • Google Analytics - For more information on Google Analytics cookies, visit www.google.com/policies. To opt-out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout. This will allow you to download and install a Google Analytics cookie-free web browser.

Facebook, Twitter and other Social Network Cookies. Our content pages allow you to share content appearing on our Website and Services to your social media accounts through the "Like," "Tweet," or similar buttons displayed on such pages. To accomplish this Service, we embed code that such third party social networks provide and that we do not control. These buttons know that you are logged in to your social network account and therefore such social networks could also know that you are viewing the JD Supra Website.

Controlling and Deleting Cookies

If you would like to change how a browser uses cookies, including blocking or deleting cookies from the JD Supra Website and Services you can do so by changing the settings in your web browser. To control cookies, most browsers allow you to either accept or reject all cookies, only accept certain types of cookies, or prompt you every time a site wishes to save a cookie. It's also easy to delete cookies that are already saved on your device by a browser.

The processes for controlling and deleting cookies vary depending on which browser you use. To find out how to do so with a particular browser, you can use your browser's "Help" function or alternatively, you can visit http://www.aboutcookies.org which explains, step-by-step, how to control and delete cookies in most browsers.

Updates to This Policy

We may update this cookie policy and our Privacy Policy from time-to-time, particularly as technology changes. You can always check this page for the latest version. We may also notify you of changes to our privacy policy by email.

Contacting JD Supra

If you have any questions about how we use cookies and other tracking technologies, please contact us at: privacy@jdsupra.com.

- hide

This website uses cookies to improve user experience, track anonymous site usage, store authorization tokens and permit sharing on social media networks. By continuing to browse this website you accept the use of cookies. Click here to read more about how we use cookies.