"DOJ Prevails in Challenge to Bazaarvoice Acquisition of PowerReviews"

by Skadden, Arps, Slate, Meagher & Flom LLP

On January 8, 2014, the Department of Justice (DOJ) prevailed in its challenge to Bazaarvoice’s consummated $168 million acquisition of PowerReviews.1 The United States District Court for the Northern District of California held that Bazaarvoice’s June 2012 deal constituted the purchase of its “closest and only serious competitor” and violated Section 7 of the Clayton Act.2 In reaching its decision, the court thoroughly applied the 2010 Horizontal Merger Guidelines (2010 Guidelines) and relied heavily on premerger “hot documents” that reflected closeness of competition between the merged parties and an anticompetitive deal rationale. Bazaarvoice demonstrates that Section 7 defendants may find it very difficult to overcome an abundance of negative premerger documents with expert economic testimony or customer testimony at trial.

Bazaarvoice joins 2011’s H&R Block3 on the DOJ’s list of successfully litigated challenges to mergers. These prominent trial victories, along with several other recent merger challenges that ended short of trial, highlight the DOJ’s current aggressive enforcement stance and its ability to intervene in mergers.


Bazaarvoice creates and markets online product reviews and ratings platforms (R&R), which allow Internet retailers to embed such reviews on their websites. PowerReviews, which was a privately held corporation, engaged in the same business until the time of acquisition.4 The parties did not file an HSR Form with the government prior to the merger because the deal’s value was below the statutory reporting thresholds.

Days after the merger closed, the DOJ began a Section 7 investigation. The DOJ built much of its case around a series of premerger Bazaarvoice documents describing the transaction in terms consistent with the allegation that Bazaarvoice sought, through the acquisition of PowerReviews, to lessen competition in the United States R&R market. On January 10, 2013, the DOJ filed suit seeking an injunction that would require Bazaarvoice to divest sufficient assets to create a new R&R competitor comparable to PowerReviews.5

The trial proceedings included depositions of 104 Bazaarvoice customers, testimony from numerous executives of both companies, and economic analysis from both the DOJ and the two parties. On January 9, 2014, the court issued a redacted public version of its opinion finding against Bazaarvoice on the issue of liability, but leaving consideration of the remedy for a later date.6

The Opinion

The court spent a great deal of its opinion discussing Bazaarvoice’s rationale for acquiring PowerReviews before turning to market definition and market concentration. The court determined that Bazaarvoice’s premerger rationale for pursuing the transaction was much different than the rationale Bazaarvoice presented at trial. “Hot documents” were the focal point of the DOJ’s trial case and the court liberally cited these documents in its opinion.7 The court noted that “[w]hile Bazaarvoice fought against every material argument of the government, its defenses were often undermined by pre-acquisition statements from its and PowerReview’s executives,” showing that “Bazaarvoice’s management believed that the purchase of PowerReviews would eliminate its only real competitor.”8 For example, premerger documents noted that the transaction would “[e]liminate [Bazaarvoice’s] primary competitor” as well as “reduc[e] comparative pricing pressure.”9 The court pointed to a plethora of premerger documents reflecting that Bazaarvoice viewed the market as a duopoly and that the primary benefit to the merger would be a reduction in competition.

The court next performed a structural market analysis, defining the relevant markets and assessing market concentration. Notably, the court acknowledged in dicta that market definition might not be necessary under Section 7, citing to the 2010 Guidelines,10 but proceeded to define relevant product and geographic markets. Accepting the markets proposed by the DOJ, the court defined the relevant product market as R&R and the relevant geographic market as the United States.11 In defining the relevant markets, the court relied upon the 2010 Guidelines’ “hypothetical monopolist” test.12

The court found a prima facie violation based on Bazaarvoice’s high post-merger market share and market concentration.13 DOJ’s estimated that Bazaarvoice’s post-merger R&R share of the top 500 internet retailers was 68 percent, and post-merger R&R revenue was 83 percent, both of which the court found warranted a presumption of anticompetitive effects.14 The court also credited the DOJ economist’s use of Herfindahl-Hirschmann Index figures, as called for in the 2010 Guidelines, to establish that the merger created a presumption of substantial post-merger reduction in competition.15 At trial, Bazaarvoice objected to the DOJ’s characterization of premerger market shares and described PowerReviews as a weak competitor. However, the court pointed to the many premerger documents reflecting close competition between the parties and noted that Bazaarvoice’s position was “often undermined by pre-acquisition statements from its and PowerReviews’ executives.”16

Bazaarvoice claimed that the acquisition was intended to strengthen the combined firm’s ability to compete in the broader online commerce market and that “architectural improvements” and syndication of content across customers resulting specifically from the transaction would create efficiencies benefiting competition after the merger. The court held that Section 7 prevents such attempts to obtain competitive “breathing space” in one market to expand into others.17 The court also found that none of Bazaarvoice’s proffered benefits were specific to the transaction or could not be done on a standalone basis.18

The court rejected Bazaarvoice’s contention that all 104 customers deposed had not complained about the merger. The court noted that Bazaarvoice may have mitigated any anticompetitive post-merger behavior in light of DOJ’s investigation,19 and that each customer negotiates price individually and is therefore unlikely to have the appropriate view of the market needed to assess whether the merger harmed it.20 The court instead credited the DOJ expert’s testimony that the deal likely would result in anticompetitive effects, suggesting that the customer testimony was not necessarily a valid proxy for the likelihood of competitive effects. The court also rejected Bazaarvoice’s citation to post-merger evidence as a means of showing that the merger had not been anticompetitive.21

The court was not swayed by Bazaarvoice’s contention that actual or prospective entrants such as Amazon, Facebook or Google would mitigate anticompetitive effects. The court found that Bazaarvoice “gave no reason why those firms were likely to enter the market” and that “syndication, switching costs, intellectual property/know how, and reputation are formidable barriers to new firms entering the market for R&R platforms and to existing R&R providers expanding their operations to replace the competition previously provided by PowerReviews.”22

Finally, the court rejected Bazaarvoice’s contention that a Ninth Circuit case, United States v. Syufy Enterprises,23 necessitated an “alternative methodology” to the traditional burden-shifting paradigm of antitrust review where consummated transactions are involved. The court distinguished Syufy as turning on the very low barriers to entry in the post-merger market — a contention that it had rejected already with regard to Bazaarvoice.


Following the DOJ’s 2011 trial success in H&R Block, Bazaarvoice represents the second litigated case resulting in a court decision that applied an analytical framework closely following the 2010 Horizontal Merger Guidelines, and both trial victories will serve as precedent against future Section 7 defendants. The cases are somewhat different in terms of market dynamics and theories of harm — H&R Block involved a 3-to-2 merger and both coordinated and unilateral effects, while Bazaarvoice was litigated as a 2-to-1 merger and a unilateral effects theory of harm. However, the courts in both cases thoroughly applied the 2010 Guidelines throughout their analyses. In both decisions, the courts found a presumption of anticompetitive effects in accordance with the 2010 Guidelines and case law and used the 2010 Guidelines’ recommended framework for analyzing the competitive effects of mergers.24 Both courts also endorsed and credited the use of expert economic analysis to support findings of likely anticompetitive effects.

Bazaarvoice reflects the critical role business documents can play in Section 7 litigation. During trial, the DOJ focused heavily on “hot documents,” and the court cited these documents throughout its opinion. Bazaarvoice’s expert testimony, purported rationale for the acquisition and customer testimony could not overcome the implications of the premerger documents suggesting that PowerReviews was the only meaningful competitor to Bazaarvoice and that the deal would lessen competition.

The court’s focus on documentary evidence and discounting of the defendant’s economic testimony reflects a dichotomy between defending mergers in court and defending mergers before the antitrust agencies. The critical evidentiary focus in merger defense at the agency level likely will differ from the evidentiary focus before a federal court. Merging parties should consider that the DOJ may place greater emphasis on economic analysis and actual market dynamics than on documents in deciding whether transactions are likely to be anticompetitive. On the other hand, courts may tend to view documentary evidence as critical, notwithstanding economic testimony to the contrary. This dichotomy between merger review at the agencies and merger review in court takes on increasing importance given the DOJ’s recent series of aggressive enforcement actions that derailed, delayed, or altered transactions without proceeding to trial: United States v. AT&T, Inc.,25 United States v. Anheuser-Busch InBev SA/NV26 and United States v. U.S. Airways Group.27

Bazaarvoice also reflects the willingness of the DOJ and the FTC to challenge consummated mergers that are not reportable under Hart-Scott-Rodino. Thus, notwithstanding the fact that a contemplated transaction does not meet the HSR reporting thresholds, parties must be aware of the statements contained in their internal documents, particularly those that present the commercial rationale for the transaction.

Finally, the case presents a significant win for the DOJ in a dynamic, technology-based market. This is especially true given the DOJ’s loss at trial in its 2004 challenge to the Oracle/PeopleSoft transaction. The court acknowledged the debate surrounding the role of antitrust law in rapidly changing technology markets, but concluded that Bazaarvoice did not present evidence to show why the dynamic aspects of the market would prevent the merger’s anticompetitive effects.28


1 U.S. v. Bazaarvoice, Inc., 13-cv-00133-WHO, slip op. (N.D. Cal., Jan. 8, 2014).

2 15 U.S.C. § 18.

3 U.S. v. H&R Block, Inc., 833 F.Supp.2d 36 (D.D.C. 2011).

4 See Bazaarvoice, slip op. at 10-11.

5 Id. at 4; see also Complaint at 20, U.S. v. Bazaarvoice, Inc., 13-cv-00133-WHO (N.D. Cal., Jan. 8, 2014).

6 Bazaarvoice, slip op. at 1-10.

7 Id. at 36-41.

8 Id. at 9.

9 Id. at 32 (internal quotations omitted).

10 Id. at 54.

11 Id. at 124-127.

12 Id. at 54-55.

13 Id. at 127-130.

14 Id. at 128.

15 Id. at 68.

16 Id. at 9.

17 Id. at 7.

18 Id. at 135-36.

19 Id. at 136.

20 Id. at 8.

21 Id. at 136-38.

22 Id. at 133.

23 903 F.2d 659 (9th Cir. 1990).

24 See, e.g., H&R Block, 833 F.Supp.2d at 71.

25 Complaint, 11-cv-01560 (D.D.C. Aug. 31, 2011).

26 Final Judgment, 13-cv-00127 (D.D.C. Oct. 24, 2013).

27 Proposed Final Judgment, 13-cv-01236 (D.D.C. Nov. 11, 2013).

28 Bazaarvoice, slip op. at 141.

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

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 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.