December 2016 Independent Contractor Misclassification and Compliance News Update

Pepper Hamilton LLP

In our update below for last month’s developments in this area of the law, we report on five significant court cases involving companies in the transportation industry that use ICs as an integral part of their business model. Each of the cases suggests rough sailing for such businesses if they do not enhance their compliance with IC laws.

As we reported in our last blog post, the U.S. Department of Labor has stated that “Even if you are a legitimate independent contractor under one law, you may still be an employee under other laws.” Enhancement of IC compliance, therefore, requires a deep understanding not only of the tests for IC status under various federal laws but, even more importantly, a solid understanding of IC tests under all applicable state laws.

In our 2015 White Paper on “How Companies Can Minimize the Risks of Independent Contractor Misclassification,” we stated that a compliance analysis using a process such as IC Diagnostics™ “should measure the company’s anticipated compliance with each of the applicable independent contractor laws. . . . Even for businesses that operate in those states that have strict tests for determining independent contractor status, this process can provide an assessment of how [best to] minimize or eliminate future misclassification liability.”

Lastly, we report on an NLRB case where a complaint was issued against a nationwide home improvement retailer for literally doing nothing more than treating certain workers as independent contractors and requiring them to sign agreements treating them as such including arbitration agreements with a class action waiver. Previously, all other NLRB complaints involving independent contractors alleged traditional violations of the National Labor Relations Act, such as threats and interrogations regarding protected activity, if the workers involved were employees under the NLRA and not ICs. In those cases, the claim that the company had violated the NLRA by misclassifying workers as ICs can be viewed as an “add on” unfair labor practice charge.

In this latest NLRB case, because the Board regards the waiver of the right to bring or join a class and collective action as an independent violation of the NLRA, the General Counsel of the NLRB may well have pleaded the misclassification charge as an “add on.” These types of IC complaints may continue to be issued until the term of the current General Counsel, a former top lawyer for a leading industrial union, expires in November 2017 and a new General Counsel is appointed by the incoming President.

In the Courts (5 cases)

MASSACHUSETTS HIGH COURT REVERSES WIN FOR “LAST MILE” LOGISTICS COMPANY IN IC MISCLASSIFICATION CASE. The highest state court in Massachusetts reverses a grant of summary judgment in an IC misclassification class action by drivers against RDI Logistics, Inc., a furniture delivery company that provides “last mile” delivery services for large retail companies. The Supreme Judicial Court of Massachusetts rejected the company’s argument that the Massachusetts IC misclassification statute was pre-empted in its entirety by the Federal Aviation Administration Authorization Act (FAAAA).  It concluded that while a portion (Prong 2) of the three-pronged statutory test for IC status is pre-empted by the FAAAA for businesses in this industry, the remaining portions (Prongs 1 and 3) were severable and that the company was required to show that both of those remaining two prongs were met if it wished to defeat the drivers’ IC misclassification claim.

Summary judgment was also reversed on the ground that the drivers lacked standing to bring suit under the IC statute because the statute’s protections apply only to “individuals” who perform services and the drivers, in contracting with the company, did so through their own corporate entities, thereby foreclosing any IC misclassification claims. The court stated that the statute does not expressly exclude individuals who provide services through a corporation and referenced the state Attorney General’s Advisory, which noted that businesses created and maintained in order to avoid application of the IC statute would not immunize employers against enforcement. The court concluded that there were enough facts presented by the plaintiff drivers to establish a genuine issue of fact as to whether the drivers have standing under the law, including evidence that the drivers formed corporations only to be able to contract with RDI, the drivers did not perform work for anyone other than RDI, and the drivers were forbidden from performing work for any other companies besides RDI. In the court’s view, “[t]hese allegations raise the question whether the plaintiffs incorporated for their own benefit, as the defendants’ suggest, or whether RDI required them to incorporate in order to misclassify them as independent contractors.” Chambers v. RDI Logistics Inc., No. SJC-12080 (Sup. Jud. Ct. Mass. Dec. 16, 2016).

CALIFORNIA COURT DENIES MOTIONS FOR SUMMARY JUDGMENT IN IC MISCLASSIFICATION CLASS ACTION AGAINST ANOTHER LOGISTICS COMPANY AND ORDERS CASE TO TRIAL. A California federal court denies competing summary judgment motions brought by the same day delivery, logistics, and courier service, Dynamex Operations West, LLC, and by individual drivers in an IC misclassification collective action under the FLSA for unpaid minimum wage and overtime compensation. Two years after the commencement of the 2013 action, the Court issued an order in October 2015 conditionally certifying a collective action of all drivers who performed delivery work for Dynamex in California who signed the same IC agreement. In September 2016, the court denied Dynamex’s motion to decertify the collective action, and counsel for plaintiffs was directed to identify the single individual with the strongest case for misclassification against Dynamex. Both sides were then invited to bring summary judgment motions regarding that selected individual driver. On December 4, 2016, the Court denied the motions of both parties regarding misclassification, concluding that there were too many fact issues to grant either side’s motion. Among the issues to be tried included whether or not the drivers were required to wear a uniform, whether the drivers actually wore one, and whether it was a customer requirement; whether there were mandatory meetings for the driver; and how the driver received the details of his deliveries. Saravia v. Dynamex, Inc., No. C 14-05003 (N.D. Cal. Dec. 4, 2016).

NEW YORK FEDERAL COURT DENIES FEDEX GROUND’S MOTION TO DISMISS IC MISCLASSIFICATION CLASS ACTION. A New York federal court denies FedEx Ground’s motion to dismiss class action claims of IC misclassification and unlawful deductions from pay under the New York Labor Law and the state’s Commercial Goods Transportation Industry Fair Play Act.  According to the complaint, the drivers, who each signed Operating Agreements with FedEx, alleged that they were directed and controlled by FedEx, not only as to the result to be accomplished, but also  as to the manner and means by which the result was to be accomplished, including supervision by FedEx managers; required compliance with detailed instructions regarding written and unwritten company policies, procedures and directives; required training and attendance at meetings for drivers; requirements that drivers use specific FedEx signage and logos on trucks; and payments from FedEx to drivers that were subject to deductions to cover use of FedEx scanner, cost of FedEx uniforms, liability and workers’ compensation insurance, performance-based penalties, and truck lease payments. In allowing the putative class action to proceed, the federal court concluded that the drivers had plausibly alleged that they were employees under the New York common law test, regardless of whether they had been labeled as ICs under the Operating Agreements, and rejected FedEx’s argument that “it is not a ‘commercial goods transportation contractor’ under the Fair Play Act because pursuant to the Operating Agreements, FedEx Ground did not pay the Plaintiffs directly, but rather paid ‘the companies they drove for.’” Padovano v. FedEx Ground Package System Inc., No.16-cv-00017 (W.D.N.Y. Dec. 6, 2016).

UBER CANNOT DISMISS DRIVERS’ “ON CALL” WAGE CLAIM IN IC MISCLASSIFICATION CASE. A Pennsylvania federal court denies Uber’s motion to dismiss an “on-call” wage claim in an IC misclassification class action lawsuit filed against Uber by UberBLACK limousine drivers.  The drivers assert claims for unpaid minimum wage and overtime and include a claim for payment of hours during which they were “logged into” the Uber app. As more fully discussed in our blog post of December 16, 2016, the drivers claimed that they are “on call” while logged on to the Uber app awaiting ride requests.  In response, Uber argued that the drivers failed to allege any facts to suggest that they were “actually working” within the meaning of the law, “just because they were logged in.” In its decision, the Court cited Supreme Court and Third Circuit precedent and Department of Labor regulations that on-call time may be compensable if the time “on call” is so restricted that it interferes with the driver’s personal pursuits. In reaching its decision, the Court referenced the allegation that drivers who refuse a fare are subject to suspension and termination.  The court concluded that the allegations were sufficient to plead a viable claim that the drivers were restricted in their personal pursuits. This case may well spur plaintiffs’ class action lawyers to bring more “on-call” wage claims against on-demand businesses that use ICs to provide in-person services to their customers. Razak v. Uber Technologies, No. 16-cv-573 (E.D. Pa. Dec. 14, 2016).

FLOWER FOODS AGREES TO PAY $9 MILLION IN SETTLEMENT OF DISTRIBUTORS’ IC MISCLASSIFICATION CASE. Flowers Foods Inc., one of the largest producers of packaged bakery foods in the United States, including Wonder Bread, agreed to settle a class action lawsuit brought against it by bakery foods distributors who alleged they were misclassified as independent contractors. The proposed settlement amount of $9 million to resolve claims brought under the federal Fair Labor Standards Act and North Carolina wage laws is subject to court approval. Flowers Foods filed a Form 8-K with the U.S. Securities and Exchange Commission advising shareholders that the proposed agreement includes $5.2 million in settlement funds and $3.8 million in attorneys’ fees. The settlement covers approximately 270 distributors as well as other non-economic terms that are intended to strengthen and enhance the IC model which remains in place. Rehberg v. Flowers Foods, Inc., No. 12-cv-596 (W.D.N.C. Dec. 9, 2016). 

Administrative and Regulatory Initiatives (2 items)

LABOR DEPARTMENT CREATES NEW IC MISCLASSIFICATION WAGE PAGE THAT MAY ENCOURAGE 1099’ERS TO FILE CLAIMS AGAINST BUSINESSES. The U.S. Department of Labor creates a new independent contractor misclassification web page,, which may encourage workers to file complaints and prompt businesses to enhance IC compliance. As discussed in our blog post of December 19, 2016, the Labor Department reissued its resources on IC misclassification and grouped them together with resources from other federal and state agencies on the subject. Our review of the posted materials reveal that no new useful information was included. Rather, the new web page included some the items that were more than 15 years old and others were more likely to confound and confuse those consulting the web page for assistance and education. The web page also highlights links to “Myths about Misclassification” and an abbreviated version of the “Myths” web page. As we reported in our blog post of August 22, 2016, the “Myths” document when issued was not an accurate restatement of the law.  Following our blog post, the Labor Department subsequently took down the page, made some revisions, and reissued it, yet still perpetuated its misapprehension that the test for IC status under the FLSA is a one-factor test – economic dependence. One likely impact of the new site will be increased awareness by workers that they may be misclassified, increased reporting and filing of complaints or enforcement actions by state and federal agencies, and more class action suits alleging IC misclassification. Another likely result is that more businesses will seek to enhance their IC compliance by the use resources like IC Diagnostics™ to minimize their risk of IC misclassification liability.

NLRB ISSUES ANOTHER IC MISCLASSIFICATION COMPLAINT. The Minneapolis regional office of National Labor Relations Board issues a complaint against Wisconsin-based national home improvement retailer, Menards, alleging that the company misclassified thousands of delivery drivers as ICs and not employees in violation of the National Labor Relations Act. The complaint, based on charges brought by the Office and Professional Employees International Union Local 153 in August and September 2016, alleges that the company interfered, restrained and coerced employees in the exercise of their Section 7 rights by maintaining a mandatory arbitration clause in its employee handbook that prohibits workers from filing collective or class-wide legal actions in any forum, legal or arbitral and prohibits them from filing unfair labor practices with the NLRB; and misclassifying the delivery drivers as ICs. According to the complaint, the remedies being sought by the NLRB include an order requiring the company to rescind or revise the mandatory arbitration clause on a nationwide basis and rescind or revise any portion of any agreements classifying the drivers as ICs NLRA; and for the company to cease and desist from communicating to the drivers that they are ICs under the NLRA. Unlike prior complaints issued by the NLRB against a company that allegedly has misclassified employees as ICs, there are no independent violations of the NLRA alleged in this case that are not dependent on the classification of the workers. Menard, Inc. v. Local 153, Office & Professional Employees International Union, AFL-CIO, Case 18-CA-181821 (NLRB Region 18, Dec. 22, 2016).

Written by:

Pepper Hamilton LLP

Pepper Hamilton LLP on:

Readers' Choice 2017
Reporters on Deadline

Related Case Law

"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.