Advertising Law -- Jan 16, 2014

Manatt, Phelps & Phillips, LLP
Contact

In This Issue:

FTC Makes New Year’s Resolution to Target Deceptive Weight-Loss Claims

While many Americans made New Year’s resolutions to lose weight or get in better shape, the Federal Trade Commission resolved to eliminate deceptive weight-loss marketing claims.

At the agency’s first press conference of 2014, Jessica Rich, director of the FTC’s Bureau of Consumer Protection, announced four settlements targeting deceptive weight-loss ads as part of “Operation Failed Resolution.”

First, and most significantly, Sensa agreed to pay $26.5 million – the second-largest amount ever recovered in a deceptive advertising settlement by the agency – for claims that its product was clinically proven to result in a weight loss of 30 pounds in six months without diet or exercise. Sensa – a product that consumers were instructed to sprinkle on their food to help them feel full and stop eating sooner – cost consumers about $60 per month.

According to the agency’s complaint, the claims were false and the studies touted in Sensa’s ads were fatally flawed. The agency also alleged that some of the consumers featured in endorsements were compensated with money and free trips.

In addition to the record Sensa settlement, the defendants – the corporate entities, CEO Adam Goldenberg, and product creator and part owner Dr. Alan Hirsch – are prohibited from making any claims about weight-loss products without two adequate and well-controlled human clinical studies.

The second suit involved New York-based L’Occitane. Skin creams like Almond Shaping Delight promised to trim inches off of users’ thighs and “visibly refine and sculpt the silhouette.” Again, the agency said the studies relied upon by the defendant were flawed – neither placebo-controlled nor blinded – and the results were exaggerated. In a proposed consent decree, L’Occitane agreed to provide $450,000 for consumer redress.

HCG Diet Direct offered a homeopathic liquid drop that included a hormone produced by the human placenta that would allegedly cause a loss of 7 pounds in 7 days or 40 pounds in 40 days. Rich said some of the consumer endorsers for the product were paid while others were related to the company’s owner. The FTC additionally challenged HCG’s claim that the product was “safe,” because the defendant urged users to restrict themselves to a 500-calorie-per-day diet, an inherently unsafe practice. While the $3.2 million judgment was suspended based on an inability to pay, the company was enjoined from disseminating future misleading claims by the settlement agreement.

Finally, Rich announced an update in prior litigation brought in conjunction with the Connecticut Attorney General against a dietary supplement maker. That company claimed that various products could produce a 25-pound weight loss in four weeks without diet or exercise. While litigation continues against several defendants, the company and its principals reached a deal with the agency and the state that prohibits false claims of rapid and substantial weight loss and requires the surrender of more than $7 million in assets.

In addition to the enforcement actions, the agency revealed a new Web site for consumers as well as Gut Check, a new tutorial for media. Ads for the products challenged in the enforcement actions “ran in trusted, nationally known publications,” Rich stated at the press conference, adding that consumers are more likely to believe claims they read in their favorite magazines or see on their favorite television stations.

In 75 letters sent to publishers, media groups, and trade associations, the FTC urged media to be a “front-line defense” to the airing of deceptive weight-loss claims. The letters and tutorial are not meant to be a shot across the bow for media, Rich noted, but “a request for teamwork” to eliminate bogus ads.

To read the complaints against the various defendants as well as the proposed settlements and consent orders, click here

Why it matters: Operation Failed Resolution is the latest effort by the FTC to stamp out deceptive weight-loss claims. Rich said the agency has filed dozens of cases against fraudulent body-slimming claims spanning decades and will “periodically bring new cases and new sweeps both to deter conduct by companies in this area and also remind consumers about the fact that many of the claims in this area are not accurate and they should be very wary of them.”

Senate Report on Data Broker Industry Released; Will Legislation Follow?

After a yearlong investigation into the data broker industry, Sen. Jay Rockefeller (D-W.Va.) released a report at a recent Senate Commerce Committee hearing at which he claimed to be “revolted” by some of the industry’s practices.

The 36-page report titled “A Review of the Data Broker Industry: Collection, Use, and Sale of Consumer Data for Marketing Purposes” made four conclusions: (1) that data brokers “collect a huge volume of detailed information on hundreds of millions of consumers,” (2) identify and classify “financially vulnerable” consumers, (3) offer products that combine both online and offline data, and (4) “operate[s] behind a veil of secrecy.”

At the Commerce Committee hearing to discuss the report, Sen. Rockefeller had harsh words for the industry, particularly the classification of consumers. He took particular issue with the creation of categories like “Ethnic Second-City Strugglers” and “Tough Start: Young Single Parents.”

The sales of such categorical lists of consumers “seem tailor made to businesses that seek to take advantage of consumers,” Sen. Rockefeller added.

He also criticized three of the nine companies from which he sought information for the report for their failure to reveal more information about their data sources. Sen. Rockefeller cautioned that he was “putting these three companies on notice today that I am not satisfied with their responses and am considering further steps I can take to get this information.”

Sen. Rockefeller also signaled his intent to continue to focus on the industry: “I’m here to say this is a very serious situation. . . . We’ve got to continue on this thing.”

To read the report, click here.

Why it matters: The report does not call for legislation, but speculation abounds that the senator will introduce a bill before his impending retirement, which will occur at the end of his current term. Coupled with a recent report from the Government Accountability Office recommending that federal legislation be passed to create baseline privacy rules for data collection, sale, and use, Sen. Rockefeller’s focus on the industry could lead to changes for data brokers – a move still being fought by the Direct Marketing Association. In a statement in response to Sen. Rockefeller’s report, DMA president Linda Woolley cited a recent study that found the data-driven marketing economy generated $156 million in revenue in 2012 and created more than 675,000 jobs. “It is disappointing that after a year and a half of cooperation from industry, a report from the Senate Committee charged with advancing U.S. commerce fails to recognize the tremendous value provided to consumers and the U.S. economy by the data-driven marketing industry,” she said.

FTC Reports on FY 2013, Do Not Call Registry

As 2013 came to a close, the Federal Trade Commission evaluated its own work over the prior months in a report to Congress and published the latest statistics on the Do Not Call Registry.

The agency’s annual Performance and Accountability report highlighted the FTC’s consumer protection efforts in the realm of privacy and data security, with Chairwoman Edith Ramirez referencing two notable cases. The agency brought its first action against a mobile device manufacturer, HTC America, as well as its first mobile cramming suit against Wise Media. Both companies agreed to settlements, in which HTC promised to develop and release software patches to fix the vulnerabilities found in its devices and in which Wise Media faced a permanent ban on cramming.

Fraudulent financial services was another area of focus for FY 2013. The agency targeted a defendant that offered members of the military and veterans deceptive home loan refinancing in violation of the Telemarketing Sales Rule. The FTC also charged a debt collection operation with harassing consumers, which resulted in the imposition of a $3.2 million penalty.

Looking forward, the report listed several strategic goals for the agency, including promoting “stronger privacy protections,” efforts to halt the use of new media to deceive consumers, targeting deceptive advertising relating to consumers’ health, evaluating environmental marketing claims, and protecting children in the marketplace pursuant to the recently revised Children’s Online Privacy Protection Act Rule.

With the Do Not Call Registry celebrating its tenth anniversary in 2013, the FTC published its biennial report to Congress as the number of registrants hit a new record high. As of September 2013, 223 million active numbers were on the list, an increase of more than 5.8 million registered numbers from the prior year.

The agency also highlighted its entrance into the mobile ecosystem that now allows consumers to register, verify, or submit complaints via mobile devices. Since the mobile launch, 27 percent of all registrations came from mobile devices, the report stated.

The downside of technological advances was also noted by the report. Voice over Internet protocol (VoIP) and caller ID spoofing have resulted in the rise of illegal robocalls, with a peak of around 200,000 consumer complaints filed per month. The agency’s efforts to combat the increase included a robocall summit and a public contest to develop technological solutions to the illegal calls.

To read the FTC’s performance and accountability report, click here

To read the Do Not Call Registry report, click here

Why it matters: The FTC’s annual report presented no surprises but reemphasized the areas of importance on which the agency will be focused in the coming year, notably consumer privacy and data security, as well as enforcement of the updated COPPA Rule.

Mystery Solved: Sherlock Holmes Is (Mostly) in the Public Domain

Sherlock Holmes himself might have declared “Elementary!” but U.S. District Court Judge Ruben Castillo stuck to more traditional language when he ruled that only a handful of elements about the detective remain protected by copyright.

Leslie Klinger, the author of numerous books and articles on Sherlock Holmes, sought a declaratory judgment against the estate of Sir Arthur Conan Doyle about the scope of copyright protection for the famous detective as well as other characters and story elements. Klinger faced the possibility that his new anthology of stories based on Holmesian elements would not be published after the estate demanded payment for a license.

Judge Castillo drew an immediate line dividing Doyle’s works. Sherlock Holmes first appeared in a story published in 1887, followed by 4 novels and 46 short stories – all of which have by now entered the public domain by date of their publication. However, 10 short stories were published after Jan. 1, 1923, and remain at issue.

The estate argued that since the later stories continued to develop the characters of Sherlock Holmes and Dr. John Watson, all of the character elements should remain under copyright protection until the final story enters the public domain in 2022.

The court disagreed. “It is a bedrock principle of copyright that ‘once work enters the public domain it cannot be appropriated as private (intellectual) property,’ and even the most creative of legal theories cannot trump this tenet,” Judge Castillo wrote.

Relying heavily on case law from the Second Circuit Court of Appeals, the court dismantled the characters into a public domain version and a copyrighted version. All of the pre-1923 story elements are therefore free for public use, the court said, while post-1923 story elements remain protected.

The court rejected the estate’s contention that “complex, three-dimensional” characters like Holmes and Watson should be subject to greater protected status, noting that the theory, if adopted, would leave courts without a workable legal standard and would “extend impermissibly the copyright of certain character elements of Holmes and Watson beyond their statutory period, contrary to the goals of the Copyright Act.”

Klinger’s victory was limited, however, as Judge Castillo found that the post-1923 story elements – like the character of Dr. Watson’s second wife, Sherlock Holmes’ retirement from his detective agency, and Dr. Watson’s background as an athlete – remain protected by copyright.

The elements are not events but “increments of expression” that warrant copyright protection, the court stated. Because the post-1923 short stories are based upon material from a preexisting work, they meet the definition of derivative works, with the new elements constituting “original expression” beyond what is contained in the public domain portion of Doyle’s work, the court said.

To read the opinion in Klinger v. Conan Doyle Estate, click here.

Why it matters: As explained by the court, the decision establishes a dividing line between pre-1923 publications and those that came after. Elements of Sherlock Holmes and his cohorts introduced prior to 1923 are fair game for public use (good news for the numerous books, TV shows, and movies devoted to the detective), while post-1923 elements remain protected for another eight years.

Noted and Quoted . . . Bloomberg BNA Turns to Marc Roth and Stacey Mayer for Insight on Protecting Brand Reputation

On January 14, 2014, Bloomberg BNA’s Social Media Law & Policy Report published an article coauthored by Manatt attorneys Marc Roth and Stacey Mayer titled “Protecting Brand Reputation in an Increasingly Mobile World.” The piece highlights the hot button social media issues for 2014 and discusses the potential public relations implications of high-profile social media campaigns.

The authors focused on the following issues to watch in 2014: (1) user-generated content; (2) consumer online reviews; (3) native advertising; and (4) real-time interactions with consumers. Brands need to closely monitor these trends and the related legal, regulatory and public relations risks of each. The authors note, “As social media platforms continue to develop and brands seek new ways to communicate with consumers, companies need to be aware of how regulators and industry self-regulatory bodies are applying their laws and rules (most of which are outdated and ill-equipped to address current activities) in order to avoid legal liability.”

To read the full article, click here.

 

 

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.

© Manatt, Phelps & Phillips, LLP | Attorney Advertising

Written by:

Manatt, Phelps & Phillips, LLP
Contact
more
less

Manatt, Phelps & Phillips, 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.