District Courts Rule on ATDS Post-ACA International

by Manatt, Phelps & Phillips, LLP
Contact

Manatt, Phelps & Phillips, LLP

Four recent rulings on what constitutes an automatic telephone dialing system (ATDS), after the U.S. Court of Appeals, D.C. Circuit struck down the Federal Communications Commission’s (FCC) interpretation, have produced mixed results, indicating the courts are still working through interpretation issues stemming from the formative ACA International decision.

Siding with the defendant—Maddox v. CBE Group, Inc.

The defendant asked the court to reconsider whether the defendant’s dialers constitute ATDSs under the TCPA, whether the defendant used an artificial or prerecorded voice during any of the calls made without plaintiffs’ prior express consent and whether the defendant reasonably relied on a third party’s prior express consent in calling the plaintiffs in light of the opinion.

Adopting a narrower read of what constitutes an ATDS, a Georgia federal court granted summary judgment in favor of a defendant with calling equipment that required human intervention to place calls.

In December 2016, an Internet service provider referred Bria Maddox’s account to CBE Group, Inc., for collection, providing CBE with her cellphone number. CBE then placed a total of 120 calls to Maddox’s cellphone between Dec. 22, 2016, and Feb. 24, 2017. On Feb. 28, 2017, Maddox sent CBE a letter of her intent to litigate, alleging violations of both the Telephone Consumer Protection Act (TCPA) and Fair Debt Collection Practices Act (FDCPA). She then filed suit.

CBE moved for summary judgment, arguing that it could not be liable under the TCPA because the calls were not made with an ATDS. All the calls CBE made to Maddox were done through its Manual Clicker Application (MCA), which requires human intervention—a manual “click”—to initiate a call.

All calls are initiated by CBE agents, via the MCA, and the system does not use any predictive or statistical algorithm to engage in predictive dialing, minimize the time CBE agents wait between calls or minimize the occurrence of a consumer answering a call when no CBE agent is available, the defendant explained, and the technology used by the company does not have the capacity to autodial or produce numbers to be called using a random or sequential number generator.

U.S. District Judge Steve C. Jones held that CBE’s system did not qualify as an ATDS within the meaning of Section 227(a)(1) of the statute.

“Looking to the language of section 227(a)(1), it seems the essential feature of an ATDS is that it uses ‘a random or sequential number generator,’” the court said. “Quite obviously, Defendant’s system did not generate Plaintiff’s 10-digit telephone number using a truly random or sequential number generator. Instead, Defendant’s system draws from a set list of actual phone numbers, which is how Defendant knew Plaintiff’s phone number was associated with her … debt.”

The court acknowledged that the FCC has “taken a rather different approach to interpreting section 227(a)(1),” reviewing the agency’s rulings on the issue as well as the D.C. Circuit decision in ACA International. There, the federal appellate panel struck down the FCC’s overly expansive definition of an ATDS found in its 2015 ruling.

“While ACA International was decided by the D.C. Circuit, the Court is persuaded that the decision is binding in this Circuit as well,” Judge Jones wrote. In light of that decision, he relied on the FCC’s 2003 interpretation of Section 227(a)(1), which focuses on whether a system can “dial numbers without human intervention.”

“Here, the undisputed fact is that CBE used a MCA, which requires human intervention,” the court said. Maddox argued that human intervention required CBE’s agents to manually dial each ten-digit telephone number to initiate a call, but the court said this position went too far.

“The FCC’s interpretation requires ‘human intervention,’ not that agents dial all ten digits of a phone number manually,” the court wrote. “Under Plaintiff’s sweeping interpretation, any phone with a speed-dial feature—i.e., nearly all phones—would qualify as an ATDS. This is the very kind of ‘unreasonably, and impermissibly, expansive’ interpretation that led the ACA International court to overturn the FCC’s 2015 Order.

“The focus is on whether the system can automatically dial a phone number, not whether the system makes it easier for a person to dial the number. Defendant’s system requires human intervention. Additionally, the system does not use any kind of predictive or statistical algorithm to engage in predictive dialing or minimize waiting times. For these reasons, it does not qualify as an ATDS, and Defendant is entitled to summary judgment on Plaintiff’s TCPA claims.”

To read the order in Maddox v. CBE Group, Inc., click here.

Siding with the plaintiff—McMillion v. Curtis

In another recent post-ACA International case, this time decided by Judge Yvonne Gonzalez Rogers in the Northern District of California, a defendant’s motion for reconsideration in light of the ACA International decision was denied.

ACA International

The court declined to do so, sticking with prior Ninth Circuit rulings. On the ATDS issue, “plaintiffs assert that the DAKCS/VIC dialer [used by Curtis] can dial eighty phone numbers per minute and the Global Connect dialer can dial approximately 60,000 phone numbers in a twelve-hour period.” Siding with the plaintiffs on that front, the court ruled that “[t]he D.C. Circuit’s decision in ACA International may influence a future ruling by the Ninth Circuit regarding the TCPA, but it does not itself constitute a change in the controlling law.

First, ACA International invalidated only the 2015 FCC Order—the court discusses but does not rule on the validity of the 2003 FCC Order or the 2008 FCC Order. See ACA International, 885 F.3d 687 (D.C. Cir. 2018) at 703 (finding that the FCC’s 2015 ruling, in describing the functions a device must perform to qualify as an autodialer, fails to satisfy the requirement of reasoned decision making and noting that it may be permissible for the FCC to adopt either interpretation).

Second, even if the D.C. Circuit had vacated the 2003 and 2008 FCC orders, ACA International has no bearing on pre-existing Ninth Circuit precedent. In 2009, the Ninth Circuit held that for a dialing system to be an ATDS, it “need not actually store, produce, or call randomly or sequentially generated telephone numbers, it need only have the capacity to do it.” Meyer v. Portfolio Recovery Assocs., 707 F.3d 1036, 1043 (9th Cir. 2012).

The defendant also asked the district court to stay the case pending the outcome of the Marks v Crunch San Diego appeal in the Ninth Circuit. The court declined to do so.

To read the order in McMillion v. Curtis, click here.

Siding with the plaintiff—Sessions v. Barclays Bank Delaware

In a putative TCPA class action filed in the Northern District of Georgia, U.S. District Judge Leigh Martin May denied a defendant’s Rule 12(c) motion for judgment on the pleadings based in part on the ACA International case. There, the plaintiff alleged, among other things, that the defendant “use[d] contact center software which connects to its telephony hardware that together constitute a dialing system with the capacity to store telephone numbers, generate telephone numbers from a stored database to be called either at random or in a sequence, and to dial such numbers” and that the “system has the capacity to dial thousands of numbers in a short period of time from its stored database of numbers without human intervention.” The judge had stayed the case in September 2017, waiting to see how the D.C. Circuit ruled in ACA International. Once ACA International was decided but prior to discovery, the defendant moved for a judgment on the pleadings, which Judge May denied in June 2018.

In making her decision, Judge May surveyed some of the other post-ACA International district court opinions. She noted that some courts—like the District of Arizona in Herrick—have found that “all of the FCC’s [prior] rulings with regard to definitions of an [automatic telephone dialing system, or] ATDS were vacated and thus courts can rely only on the statutory language alone.” Yet other courts—including the Northern District of Georgia in Maddox discussed above and the Southern District of Florida in Reyes—have held that other FCC orders defining some functions of an ATDS (for example, the FCC’s 2003 Order, which defined a “predictive dialer” as “equipment that dials numbers and, when certain computer software is attached, also assists telemarketers in predicting when a sales agent will be available to take calls”) are still in effect.

Rather than adopting the reasoning in the Maddox case, Judge May adopted the District of Arizona’s reasoning in Herrick and held that all of “the FCC’s prior orders with regard to interpretations of ‘capacity’ and descriptions of the statutorily enumerated functions a device must perform to be an ATDS were vacated in ACA International.” Turning to the defendant’s motion, the judge found that the plaintiff’s allegations were sufficient to allege that the defendant had used an ATDS within the meaning of the TCPA. In particular and relying primarily on pre-ACA International opinions, Judge May held that “Plaintiff repeatedly allege[d] that Defendant called her cell phone using an ATDS” and that “[a] number of courts have found that alone is enough.” She also disagreed with the defendant’s interpretation of the TCPA statutory requirement that “using a random or sequential number generator” means that the ATDS equipment must have “the ability to ‘generate and then dial random or sequential numbers.” Thus, because the exact system used by the defendant was unknown at that stage of the litigation, Judge May accepted the plaintiff’s allegations as true as required, denied the defendant’s motion and lifted the stay on discovery.

To read Sessions v. Barclays Bank Delaware click here.

Siding with the plaintiff—Ammons v. Ally Financial, Inc.

Chief Judge Waverly D. Crenshaw from the Middle District of Tennessee relied on ACA International to grant a plaintiff’s motion for summary judgment, ruling that the defendant’s phone system was an automatic telephone dialing system (ATDS). There, the plaintiff and her daughter purchased a car, during which the plaintiff had provided her cellphone number. In addition to whether the plaintiff had provided and later revoked her “prior express consent” within the meaning of the TCPA, the parties also disagreed as to whether the defendant’s calling system was an ATDS.

After walking through the FCC’s prior interpretations of an ATDS (i.e., the 2003, 2008 and 2015 FCC orders) and pondering whether any of those orders still had any import, Judge Crenshaw held that “[i]n the wake of ACA International, this Court joins the growing number of other courts [e.g., Maddox discussed above] that continue to rely on the interpretation of § 227(a)(1) [of the TCPA] set forth in prior FCC rulings” and expressly rejected the District of Arizona’s holding in Herrick, which ruled that ACA International vacated all prior FCC interpretations of an ATDS like the Northern District of Georgia did in the Sessions case discussed above. Consequently, Judge Crenshaw applied pre-ACA International case law and held that “the primary consideration [in defining a calling system as an ATDS] is whether human intervention is required at the point in time at which [Ammons’] number [was] dialed.”

Turning to the case at bar, while the defendant argued that human intervention was involved in the calls at issue after connection, Judge Crenshaw held that “[a]s a matter of common sense, having operators standing by, to use an old phrase, to take a connected call is not ‘human intervention’ in the dialer’s initiation of calls.” Thus, because the defendant had stipulated “that agents [we]re available to intervene in calls [only] after they have been initiated by the [defendant’s] predictive dialer,” the dialer was an ATDS within the meaning of Section 227(a)(1) of the TCPA.

To read Ammons v. Ally Financial, Inc. click here.

 

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

© Manatt, Phelps & Phillips, LLP | Attorney Advertising

Written by:

Manatt, Phelps & Phillips, LLP
Contact
more
less

Manatt, Phelps & Phillips, LLP on:

Readers' Choice 2017
Reporters on Deadline

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

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

JD Supra Privacy Policy

Updated: May 25, 2018:

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

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

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

Collection of Information

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

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

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

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

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

How do we use this information?

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

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

How is your information shared?

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

How We Protect Your Information

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

Children's Information

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

Links to Other Websites

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

Information for EU and Swiss Residents

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

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

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

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

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

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

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

California Privacy Rights

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

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

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

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

Access/Correct/Update/Delete Personal Information

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

Changes in Our Privacy Policy

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

Contacting JD Supra

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

JD Supra Cookie Guide

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

How We Use Cookies and Other Tracking Technologies

We use cookies and other tracking technologies to:

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

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

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

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

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

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

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

Controlling and Deleting Cookies

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

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

Updates to This Policy

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

Contacting JD Supra

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

- hide

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