Commerce Department Takes Steps To Thwart Use of Information and Communications Technology and Services Associated With Foreign Adversaries

Skadden, Arps, Slate, Meagher & Flom LLP

On November 27, 2019, the U.S. Department of Commerce (Commerce) published a proposed rule that would establish a new and especially broad power for the U.S. government to review and potentially block or unwind transactions involving foreign Information and Communications Technology and Services (ICTS). This sweeping new authority would allow Commerce to unilaterally review and prevent any foreign ICTS-related transaction in the United States or involving U.S. persons. As outlined in our summary of President Trump’s May 15, 2019, Executive Order finding a threat to U.S. national security arising from the acquisition and use in the United States of ICTS supplied by “foreign adversaries” (available here), this proposed rule was expected to detail the new review regime, including standards of jurisdiction, procedures for review and criteria for potential exclusions. However, the rule’s scope, limitations on authority and review process itself lack detail and clarity — creating significant uncertainty as to the scope and potential impacts of the proposed rule. Importantly for dealmakers and industry, the proposed rule does not include a safe-harbor provision to reduce transactional risk.

Commerce has requested written comments, which must be submitted by December 27, 2019.

Summary of Proposed Rule

Scope of Covered Transactions

The proposed rule would give Commerce (in consultation with several other departments and agencies) discretion to review a broad array of “transactions” on a case-by-case basis, including any “acquisition, importation, transfer, installation, dealing in, or use of any [ICTS]” that: (i) involves any person or property subject to U.S. jurisdiction; (ii) involves property, technology or a service in which any foreign country or foreign person has an interest; and (iii) is initiated, pending or will be completed after May 15, 2019. Notably, ongoing managed services, software updates, or repair services meeting these criteria, even if associated with contracts executed before May 15, 2019, would potentially be subject to review. There are no U.S. dollar or other thresholds that would limit the expansive scope of the transactions potentially subject to review.

Commerce specifically declined to recognize any particular technologies or particular participants in the market for ICTS as categorically included or excluded from the prohibitions established by the Executive Order, opting instead for a case-by-case, fact-specific approach that would enable the targeting and prohibition of transactions “without unintentionally prohibiting other transactions involving similar ICTS that may not rise to the level of presenting an undue risk to critical infrastructure or the digital economy in the United States or an unacceptable risk to national security or the safety of U.S. persons.” However, the broad definitions in the proposed rule dramatically expand the scope of potentially covered transactions.

First, ICTS is broadly defined, as in the Executive Order, to include “any hardware, software, or other product or service primarily intended to fulfill or enable the function of information or data processing, storage, retrieval, or communication by electronic means, including through transmission, storage, or display.”

Second, a transaction would be potentially subject to review if it involves ICTS “designed, developed, manufactured, or supplied by persons owned by, controlled by, or subject to the jurisdiction or direction of a foreign adversary.” As drafted, however, the proposed rule does not specify what constitutes “subject to the jurisdiction of a foreign adversary.” Thus at least for now, under a plain reading of the regulation, even a non-U.S. subsidiary that is organized and located in a jurisdiction determined to be a foreign adversary potentially could be implicated. Commerce did, however, enumerate certain factors that would inform its determinations regarding ownership, control and foreign adversary jurisdiction, specifically “the laws and practices of the foreign adversary; equity interest, access rights, seats on a board of directors or other governing body, contractual arrangements, voting rights, and control over design plans, operations, hiring decisions, or business plan development.”

Third, Commerce also did not further expand upon the definition of “foreign adversary,” which, as in the Executive Order, is characterized as “any foreign government or non-government person determined by the Secretary to have engaged in a long-term pattern or serious instances of conduct significantly adverse to the national security of the United States or security and safety of United States persons.” Commerce specifically noted that “foreign adversary” determinations are exclusively a matter of executive branch discretion and therefore declined to identify any such governments or persons. Such an approach would almost certainly apply to China.

As currently contemplated, these definitions and the scope of covered transactions will subject an extremely wide-range of ongoing or contemplated ICTS transactions to review and potential resulting mitigation, including either blocking or unwinding. Commerce has requested comments on whether it should consider categorical exclusions of certain types of ICTS transactions but, as noted above, it has explicitly declined to do so in the proposed rule, opting instead for a case-by-case review.

Initiation and Review Process

The proposed rule grants the Secretary of Commerce (Secretary) complete discretion to determine which transactions to review. Evaluation of a transaction is initiated in three ways: (i) at the Secretary’s discretion; (ii) upon request by another U.S. government department or agency; or (iii) based on information provided by private parties via a Commerce web portal. The latter method likely is intended to enable parties to a proposed transaction to have that transaction reviewed before proceeding given that Commerce has made clear that it will not be issuing advisory opinions or declaratory rulings with respect to any particular transaction.

Once Commerce decides to initiate review of a covered transaction, for which no timetable is established, the Secretary (in consultation with several other departments and agencies) will evaluate whether the transaction:

(i) poses an undue risk of sabotage to or subversion of the design, integrity, manufacturing, production, distribution, installation, operation, or maintenance of information and communications technology or services in the United States;

(ii) poses an undue risk of catastrophic effects on the security or resiliency of U.S. critical infrastructure or the U.S. digital economy; or

(iii) otherwise poses an unacceptable risk to U.S. national security or to the security and safety of U.S. persons.

The Secretary will then issue a preliminary determination of whether an ICTS transaction with a foreign adversary poses a risk to U.S. national security. Although Commerce has the option to contact the parties to a transaction, such a preliminary determination could be the first notice parties receive that a transaction was under review or that a particular foreign party or country is considered a “foreign adversary.” Upon receipt of the preliminary determination, parties have the option to submit an “opposition” within 30 days that the Secretary may consider in reaching a final determination on whether to mitigate, unwind or block the transaction. Final determinations are expected within 30 days of the submission of any opposition. No specific guidance exists on the likely nature, scope and duration of any mitigation, though a directive to discontinue using or even to “rip and replace” any offending hardware or software without compensation is possible. Commerce will make public a summary of each final determination.

Violations of any requirement, including failure to abide by the terms of any mitigation agreement, subject the violator to the potential imposition of civil penalties in an amount not to exceed $302,584, as adjusted for inflation, or, depending on circumstances, the value of the underlying transaction or twice the value of the underlying transaction.

Government Approach to ICTS-Related Security Vulnerabilities

The proposed rule is the latest in a years-long U.S. government effort to prevent threats to U.S. telecommunications, network and computing infrastructure. In 2012, the House Permanent Select Committee on Intelligence issued a scathing bipartisan report on efforts by Chinese companies Huawei Technologies Co. Ltd. (Huawei) and ZTE Corporation (ZTE) to infiltrate U.S. telecommunications networks and steal U.S. technology. Huawei and ZTE have since faced many legal and regulatory actions by the U.S. government, including currently pending criminal charges against Huawei for corporate espionage, wire fraud and obstruction of justice. In May 2019, Commerce added Huawei to the Entity List, which generally restricts the company’s access to U.S. technology. Similarly, Commerce temporarily added ZTE to the Denied Persons List in February 2018 after ZTE violated its 2017 agreement settling civil and criminal allegations of violating U.S. sanctions against Iran and North Korea.

On August 13, 2019, the U.S. Department of Defense, General Services Administration, and National Aeronautics and Space Administration implemented an interim rule under the John S. McCain National Defense Authorization Act for Fiscal Year 2019 (NDAA). The rule generally prohibits executive agencies from procuring telecommunications equipment and services from Huawei, ZTE and other named Chinese technology companies and imposes strict reporting and other requirements on U.S. government contractors. This legislation followed a 2018 directive issued by the U.S. Department of Defense prohibiting retail outlets on U.S. military bases from selling Huawei devices and is consistent with an effort by the U.S. government to pressure both U.S. wireless carriers and allied governments from using Huawei hardware.

On November 22, 2019, the Federal Communications Commission (FCC) adopted a Report and Order that bars telecommunications carriers from using U.S. government subsidy funds to purchase equipment and services from companies that are a national security concern — currently including only Huawei and ZTE. Under this rule, the FCC’s approximately $8.5 billion Universal Service Fund, available for U.S. carriers to expand rural and remote telecommunications infrastructure, may not be used to purchase, operate or provide services to, or involve equipment or services from, these vendors.

Although likely intended to target Chinese telecommunications equipment companies like Huawei and ZTE, the Commerce ICTS proposed rule is not limited to a particular country or specific companies, and it grants the Secretary broad discretion to designate a foreign government or foreign non-government person as a “foreign adversary.” Thus, even if the current administration’s short-term objectives are specific to threats posed by Huawei and ZTE, the proposed rule may result in a more expansive application over time.

Troubling Effects of the Proposed Rule

The proposed rule is intended to give the U.S. government a broad and powerful tool to address a problem that — in the government's view — remains vexing despite a range of existing regulatory authorities. For example, although the NDAA and implementing regulations may prevent private parties from doing business with the U.S. government by virtue of the U.S. government’s inherent control over its purchasing decisions, those provisions do not control private company decisions to implement foreign ICTS products in their private network infrastructure. Similarly, listing Huawei and ZTE on restricted party lists under U.S. export controls is a party-specific targeting that does not address more strategic concerns, nor do more traditional regulatory tools solve the U.S. government's security challenges. For example, U.S. export controls regulate the provision of U.S. goods or technology to foreign parties but lack oversight of equipment or technology purchases by U.S. persons, and while the Committee on Foreign Investment in the United States (CFIUS) reviews foreign investment in U.S. businesses, it does not have jurisdiction over a U.S. party’s acquisition of equipment from a foreign supplier.

Creating a new regulatory regime, however, as demonstrated by the proposed rule itself, poses significant complexities. As drafted, the significant discretion that the proposed rule grants to the Secretary, with few if any executable standards, may become unpredictable and create uncertainty for the telecommunications and information systems industries, leaving companies little choice but to resort to sourcing equipment from western suppliers that are less likely to be deemed adversarial, at considerable time and expense.

Many of the principles of the ICTS review process draw parallels to the CFIUS review process but, unlike the vastly more detailed CFIUS regulations developed over decades, the proposed rule’s scant seven pages fail to provide a meaningful basis for such a process. This concern manifests in multiple ways, most prominently in the lack of participation by parties contemplating a transaction. The proposed rule does not include a formal method for parties to submit a notice of a transaction (similar to the voluntary notice provisions of other review regimes, such as CFIUS or Team Telecom).1 Although the proposed rule affords parties the opportunity to submit an “opposition” after the Secretary has reached a preliminary determination, limited information and virtually no standards are provided currently to guide the Secretary in reaching a final determination.

Next Steps

As noted above, the deadline for commenting on these proposed rules is December 27, 2019. Commerce explicitly has solicited comments regarding, for example, circumstances under which categorical exclusions might be appropriate, thereby suggesting that Commerce is cognizant of the expansive scope of these proposed rules. Based on the comments received, Commerce has discretion to issue a final rule that takes comments into account. No timetable has been established for issuance of a final rule, but potentially impacted companies, including in particular, telecommunications service providers, internet and digital service providers, and vendors and equipment managers, would be well-advised to review their supply chains and forecasted needs for ICTS to evaluate the potential effects of any final rule.


1 Team Telecom is the colloquial term for the working group of representatives from the federal government charged with ensuring national security — the Departments of Homeland Security, Defense, Justice, State, Treasury, and Commerce, as well as the Office of the United States Trade Representative and the Federal Bureau of Investigation — when a foreign person invests in U.S. communications assets.

Download PDF

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.

© Skadden, Arps, Slate, Meagher & Flom LLP | Attorney Advertising

Written by:

Skadden, Arps, Slate, Meagher & Flom LLP

Skadden, Arps, Slate, Meagher & Flom 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.