Advertising Law - June 2016 #4

by Manatt, Phelps & Phillips, LLP

Manatt, Phelps & Phillips, LLP

In This Issue:
  • FTC Shuts Down Scam Touting Aid for Disabled Individuals
  • Robocall Defendants Reaped $15.6M, Regulators Charge
  • FTC Reports on Fraud in Minority Communities
  • Spokeo Backs Class Certification Denial in False Ad Suit

FTC Shuts Down Scam Touting Aid for Disabled Individuals

A telemarketer faces a Federal Trade Commission ban on claims that the sales of products would help disabled individuals.

The agency took action against Adli Dasuqui and a pair of his companies, American Handicapped Inc. and Disadvantaged Workers Inc., alleging the defendants paid telemarketers to cold-call consumers to sell light bulbs and trash bags. Callers told consumers that they represented a charitable organization that employed disabled persons or that they themselves were disabled. They claimed that a purchase (at inflated prices, such as $30 for two light bulbs or $100 for 60 trash bags), or a donation, would help disabled individuals.

Such claims were false, the FTC alleged, as the defendants paid "only a small portion to handicapped or disabled employees, the person soliciting [was] usually not handicapped or disabled, and Defendants do not operate a charitable organization." The defendants also shipped merchandise without the consent of consumers and then sought payment for the unordered merchandise, according to the agency, which cited complaints about the defendants' practices from several states including Arizona, Iowa, and Minnesota.

The Michigan federal court complaint asserted violations of Section 5 of the Federal Trade Commission Act, the Telemarketing Sales Rule, and the Unordered Merchandise Statute.

Pursuant to the stipulated final order, the defendants are prohibited from selling anything for the "purported benefit" of disabled persons, mischaracterizing their involvement in charitable endeavors, or from making untrue claims that a consumer has ordered and agreed to pay for products. Future violations of the Telemarketing Sales Rule and the Unordered Merchandise Statute are also prohibited by the order, as are misrepresenting any material fact about any good or service, profiting from customers' personal information, or failing to properly dispose such data.

A $4 million judgment was suspended due to an inability to pay.

To read the complaint and stipulated final order in FTC v. American Handicapped, Inc., click here.

Why it matters: For appealing to consumers' sense of charity by misrepresenting that purchases or donations would help handicapped or disabled individuals, the defendants ran afoul of the FTC Act and the TSR. Adding to their legal problems: they sent unordered merchandise and then charged consumers in violation of the Unordered Merchandise Statute.

Robocall Defendants Reaped $15.6M, Regulators Charge

The Federal Trade Commission working with the Florida Attorney General's Office, filed suit against a group of related defendants, charging them with "bombarding" consumers with illegal robocalls in an attempt to sell debt relief services and credit card interest rate reductions.

A federal court granted the regulators' request for a temporary restraining order halting the operation, which the FTC and AG said took in more than $15.6 million since January 2013 and made "hundreds of thousands" of robocalls.

Collectively known as Life Management Services of Orange County, LLC, the defendants used generic names like "Bank Card Services" and "Credit Assistance Program" when calling consumers, claiming to be a "licensed enrollment center" for credit card networks such as MasterCard and Visa, the FTC and AG said. The defendants promised to work with credit card companies or banks to "substantially and permanently" lower credit card interest rates and save consumers thousands of dollars by paying off their balances three to five times faster, according to the complaint filed in Florida federal court.

Instead, consumers were charged an upfront fee of between $500 and $5,000 and the defendants made, at best, a rudimentary effort to contact some credit card companies, the regulators alleged.

The defendants further deceived consumers by offering a credit card debt elimination service. By tapping into a government fund, the defendants claimed that they could pay off a consumer's debt in 18 months—for an upfront payment of between $2,500 and $20,000. Since no such fund actually exists, the consumers who paid for the purported service only found themselves deeper in debt, according to the complaint.

How did the agency obtain its evidence against the defendants? In the case against Life Management, the FTC told the court it relied upon a "telephone honeypot," a bank of phone lines designed to attract robocalls. FTC investigators were the parties answering the calls, and had the opportunity to interact with callers to identify them and document their claims.

While the action seeks a permanent stop to the defendants' operations and money for consumer refunds for violations of the Federal Trade Commission Act, the Telemarketing Sales Rule, and Florida's Deceptive and Unfair Trade Practices Act, so far the court has only ordered a temporary halt pending an upcoming hearing.

To read the complaint and the TRO in FTC v. Life Management Services of Orange County, click here.

Why it matters: The case was the 39th action taken since January 2015 as part of a collective enforcement effort with state regulators and other countries to halt robocall operations. Actions with agencies ranging from the United Kingdom's Information Commissioner's Office to the offices of the attorneys general in Colorado, Missouri, and Washington, among others, have all focused on combatting "the nuisance of illegal robocalls," the Commission explained. To further these efforts, the FTC announced that 11 international regulatory organizations signed a new memorandum of understanding "to share information and intelligence in the worldwide fight against unsolicited messages and calls." Signatories, all members of the London Action Plan, include regulatory agencies in Australia, Canada, Korea, Netherlands, New Zealand, South Africa, and the United Kingdom, with the FTC and the Federal Communications Commission signing on for the United States.

FTC Reports on Fraud in Minority Communities

Fraud in minority communities was the subject of a new report from the Federal Trade Commission issued to Congress.

"Combating Fraud in African American and Latino Communities: The FTC's Comprehensive Strategic Plan" discussed the agency's "extensive efforts to combat fraud in not only African American and Latino communities, but every community with an emphasis on raising public awareness and encouraging more fraud reports," the agency explained.

An estimated 10.8 percent of American adults, or 25.6 million people, were victims of fraud according to the most recent FTC survey, with African American and Latino consumers more likely to become victims than non-Hispanic whites (at a rate of 17.3 and 13.4 percent compared to 9.0 percent). To reduce fraud, the FTC report sets forth a three-pronged approach of prevention, law enforcement, and consumer outreach and education.

"Raising awareness of fraud in African American and Latino communities is the first step in prevention," the agency explained, adding that "Talking about fraud helps people avoid scams" as "silence contributes to financial loss."

Data suggests that minority communities underreport fraud to the FTC even though they experience it at higher rates, the FTC said. To solve this problem, the Commission intends to speak at national and regional conferences of organizations that reach African American and Latino audiences and encourage individuals to talk about and report fraud. It will discuss fraud awareness with African American and Latino media outlets to encourage reporting of scams, and launch a pilot program to visit areas with low rates of fraud related complaints.

The FTC also intends to bring more cases against entities that disproportionately prey on African American and Latino consumers (such as affinity frauds, income-related frauds, and debt-related frauds), broaden investigative resources to ensure marketplaces are not overlooked, and perform additional research to help the Commission identify and target frauds affecting minority communities.

For the final component of its strategy, the agency will build on its existing consumer outreach and education efforts to maximize the availability and accessibility of the FTC's educational materials to African American and Latino communities. To that end, consumer education materials will be made widely available in multiple formats (websites, videos, audio, and print) in both English and Spanish, with an increased use of real-life stories to engage interest in the educational campaigns.

The FTC will also continue its examination of fraud in minority communities by hosting a workshop in December on Changing Consumer Demographics. As the population of the United States grows older and more racially and ethnically diverse, the Commission will bring together researchers, marketers, community groups, and law enforcement to consider the predicted changes.

"Who will be the consumers of the future?" the report asked. "How is advertising and marketing changing? How will fraud likely change and what can the FTC and others do to prepare to combat fraud perpetuated against these new consumers? Studying these questions will help the agency continue to strategize and prepare for the years ahead."

To read the FTC's report, click here.

Why it matters: "The FTC is committed to working to promote a fair marketplace for all," the agency wrote in the report. "Combating fraud in African American and Latino communities is an important part of the FTC's fraud program and the agency looks forward to further implementing this strategic plan." Advertisers and marketers should take note of the Commission's fraud prevention strategy as well as the upcoming workshop on changing consumer demographics.

Spokeo Backs Class Certification Denial in False Ad Suit

Litigants are already seeing the effects of the Spokeo decision in action, with a California federal court judge granting an advertiser's motion to dismiss a false advertising case in reliance upon the U.S. Supreme Court's recent opinion.

In May, the high court ruled in Spokeo, Inc. v. Robins that a plaintiff must show an injury in fact before pursuing a claim for a violation of the Fair Credit Reporting Act, a federal statute that provides for statutory penalties similar to the Telephone Consumer Protection Act. The 6-2 decision authored by Justice Samuel Alito made headlines, with defense attorneys hoping it would decrease the number of consumer class actions seeking damages for mere technical violations of federal statutes.

A false advertising action out of California may further those hopes. The case involved plaintiffs who filed a putative class action against PharmaCare US, Inc. over its IntenseX dietary supplement, which the company claimed could enhance sexual power and performance.

When the plaintiffs filed a motion for class certification, the defendant relied on Spokeo to argue certification was improper because the plaintiffs failed to establish evidence that all members of the proposed nationwide class suffered an actual injury.

U.S. District Court Judge Marilyn L. Huff—who also found problems with commonality and predominance as well as typicality for the proposed class—agreed that standing issues foreclosed granting the certification motion.

"The Supreme Court recently reemphasized the importance of the Article III standing requirements, particularly the requirement of an injury that is both concrete and particularized," she said. "It wrote: 'Congress' role in identifying and elevating intangible harms does not mean that a plaintiff automatically satisfies the injury-in-fact requirement whenever a statute grants a person a statutory right and purports to authorize that person to sue to vindicate that right. Article III standing requires a concrete injury even in the context of a statutory violation."

While the plaintiffs asserted they had standing because they relied on the label claims, the product did not perform as promised, and they lost money as a result, the defendant countered that some class members lacked standing because they were not dissatisfied, were not harmed, or had no viable claim.

"Defendant points out that the proposed class includes consumers (1) who bought similarly named products not distributed by Defendant, (2) whose claims are time-barred, (3) who bought IntenseX because of the express label claims, received the benefit claimed, and are satisfied, (4) who bought IntenseX for reasons other than its advertising or labeling, (5) who suffered no injury because they would have paid the same for similar products, (6) who received a refund, and (7) who bought the product from Defendant's website and were never exposed to the alleged aphrodisiac/disease claims Plaintiffs rely on," the court said.

Although the Ninth Circuit Court of Appeals has been inconsistent about whether absent class members must have standing, Judge Huff said the plaintiffs still failed to satisfy the necessary standing requirements.

"Whether characterized as problems with overbreadth, commonality, typicality, or Article III standing, however, there is a substantial mismatch between Plaintiffs and the classes they propose to represent," the judge wrote. "The Court concludes that class certification is not proper to the extent that Plaintiffs raise claims and theories they do not have standing to raise, and to the extent that the class includes consumers who have no cognizable injury, including those who obtained full refunds."

To read the order in Sandoval v. PharmaCare, click here.

Why it matters: For companies facing putative class actions filed under consumer protection statutes such as the TCPA and the FCRA, the order denying class certification in reliance upon Spokeo holds promise. The court was clear that the U.S. Supreme Court's decision will operate to limit certification where potential class members have not suffered a cognizable injury.

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

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 (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

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 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 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 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

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:

JD Supra Cookie Guide

As with many websites, JD Supra's website (located at (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
  • New Relic - For more information on New Relic cookies, please visit
  • Google Analytics - For more information on Google Analytics cookies, visit To opt-out of being tracked by Google Analytics across all websites visit 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 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:

- 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.