Federal Circuit Review - September 2018

by Knobbe Martens

Knobbe Martens

Federal Circuit Finds Claims Issued from Reexamination Co-Pending with Appeal Ineligible Where the Changes Did Not Affect Section 101 Eligibility

In SAP AMERICA, Inc. v.  InvestPic, LLC, Appeal No. 2017-2081, the Federal Circuit held that where remanding post-reexamination claims that issued during the pendency of an appeal would be futile, the Federal Circuit may address the claims as they emerge from reexamination. 

SAP America, Inc. filed a declaratory judgment action and moved for judgment on the pleadings seeking to invalidate the claims of InvestPic’s patent under 35 U.S.C. § 101.  The district court granted the motion and InvestPic appealed.  The Federal Circuit affirmed the district court’s decision, finding that the claims reciting “statistical analyses of investment information” were directed to patent-ineligible subject matter.  InvestPic filed a petition for rehearing based on the post-reexamination issuance of new and amended claims while the appeal was pending.

The Federal Circuit found that the validity issues relating to the original claims were not moot because some claims remained unchanged in scope and because pre-change damages could potentially have been available.   Concluding that any remand for further consideration of the post-reexamination claims would have been futile, the Federal Circuit reissued and modified its opinion to address the post-reexamination claims. The Federal Circuit found that the post-reexamination claims did not change the finding of invalidity because they merely added details to the abstract ideas in the claims while adding nothing to the non-abstract elements of the claims (conventional computer and display devices). Accordingly, the Federal Circuit maintained its affirmance of the district court’s judgment.

In Appropriate Cases, a Party Advocating That a Claim Limitation That Does Not Recite the Word “Means” Is Subject to 35 U.S.C. §112 ¶ 6 Can Overcome the Presumption Solely by Reference to Intrinsic Evidence

In Diebold Nixdorf, Inc. v. ITC, Appeal No. 2017-2553, the Federal Circuit held that the term “cheque standby unit,” as used in the patent-in-suit, was a means-plus-function term subject to 35 U.S.C. §112 ¶ 6 which lacked corresponding structure disclosed in the specification.

The ITC found that Diebold violated § 337 of the Tariff Act of 1930 by importing components of automated teller machines (“ATMs”) that infringd claims of a patent owned by Hyosung TNS Inc. and Nautilus Hyosung America, Inc.  Diebold appealed.

The Federal Circuit reviewed the legal determinations of the ITC de novo and reversed the ITC’s decision.  The Federal Circuit held that the term “cheque standby unit” recited in the claims at issue was a means-plus-function term subject to 35 U.S.C. § 112 ¶ 6, which lacked corresponding structure disclosed in the specification.  Although the term did not recite the word “means,” the Federal Circuit found that Diebold had overcome the presumption that § 112 ¶ 6 did not apply.  Diebold showed that the term “cheque standby unit” both failed to recite sufficiently definite structure, and recited a function without reciting sufficient structure for performing that function.  Rejecting the ITC’s argument that Diebold had to provide evidence extrinsic to the patent, the Federal Circuit found that Diebold could overcome the presumption solely by reference to evidence intrinsic to the patent.  Diebold’s failure to contradict Hyosung’s expert’s testimony was also not fatal.  Hyosung’s expert did not introduce any evidence to support his assertion that “cheque standby unit” was a term commonly understood by persons of ordinary skill in the art to denote a device or class of devices, nor did he explain with any degree of definiteness what structure or class of structures a person of ordinary skill in the art would have understood the term to encompass.  Examining the intrinsic evidence, the Federal Circuit found that the claims and specification did not recite any structure for the “cheque standby unit,” and ultimately concluded that the claims at issue were invalid for indefiniteness.

A District Court Must Establish a Causal Connection Between Misconduct and an Award of Attorneys’ Fees

In In re: Rembrandt Techs. LP Patent Litigation, Appeal No. 2017-1784, the Federal Circuit held that the district court did not abuse its discretion by concluding that the case before it was exceptional.  The Federal Circuit reached this conclusion because (1) fact witnesses were compensated based on the outcome of the case, (2) relevant documents were destroyed, and (3) asserted patents were improperly revived during prosecution.  The Federal Circuit also held that the district court erred by failing to sufficiently assess which issues the misconduct affected to justify awarding attorneys’ fees, and remanded the issue to the district court to conduct the proper analysis of the fee award.  

Rembrandt Technologies, LLC and Rembrandt Technologies, L.P. (“Rembrandt”) filed suit against dozens of cable companies, cable equipment manufacturers and broadcast networks.  These cases were consolidated in the District of Delaware.  The district court entered judgment against Rembrandt as to all claims.  After final judgment, many of the defendants filed a motion for attorneys’ fees.  The district court determined that the case was exceptional and awarded over $51 million in attorneys’ fees.  

The district court found the case to be exceptional because Rembrandt improperly compensated its fact witnesses based on the outcome of the case, engaged in document spoliation, and should have known that two of the asserted patents had been improperly revived and were therefore unenforceable. 

The Federal Circuit reviewed the exceptional-case determination for abuse of discretion.  The Federal Circuit did not find that any of the district court’s findings were based on an erroneous view of the law or on a clearly erroneous assessment of the evidence.  First, Rembrandt’s agreement with its patent consultants granted them a stake in any litigation involving some of the asserted patents, and it was foreseeable at the time the agreement was signed that the consultants would become fact witnesses in the litigation.  Second, after the original owner of the asserted patents was retained, Rembrandt knew that documents were being destroyed at the original patent owner’s facilities, and that there was a significant risk that relevant documents were being destroyed.  Third, there was evidence that two of Rembrandt’s asserted patents had been intentionally abandoned due to the belief that the inventions lacked commercial value.  However, the patents were later revived based on a statement to the USPTO that the abandonment was unintentional.  Although Rembrandt was not involved in the prosecution, it had access to documents that outlined the strategy for the petitions to revive, and thus Rembrandt at least “should have known” that the revivals had been improper. 

In reviewing the district court’s fee award, the Federal Circuit found that the district court did not even attempt to assess which issues the misconduct affected, and therefore the district court did not establish a causal connection between the misconduct and the awarded attorney fees.  The Federal Circuit remanded to the district court to conduct the proper analysis of the fee award.    

Federal Circuit Affirms That Asserted Claims Directed to a Self-Evolving Generic Index for Organizing Information Stored in a Database Were Invalid Under 35 U.S.C. § 101

In BSG Tech LLC v. BuySeasons, Inc., Appeal No. 2017-1980, the Federal Circuit held that all asserted claims, which were directed to a “self-evolving generic index” for organizing information stored in a database, were ineligible under § 101. 

BSG Tech LLC (“BSG”) sued BuySeasons, Inc. (“BuySeasons”) for infringement of several patents related to systems and methods for indexing information stored in wide-access databases.  The patents relate to indexing software that organizes information about various items using classifications, parameters, and values.  The patents taught a “self-evolving” aspect that enables users to “add new parameters for use in describing items.”  On a motion to dismiss that was converted into a motion for summary judgment, the U.S. District Court for the Eastern District of Texas found that all of the asserted claims were invalid under 35 U.S.C. § 101.  BuySeasons subsequently appealed, and the Federal Circuit affirmed.

Under step one of Alice, the Federal Circuit agreed with the district court that the asserted claims were directed to the abstract idea of considering historical usage information while inputting data. The Federal Circuit found that this was not a method “necessarily rooted in computer technology in order to overcome a problem specifically arising in the realm of” wide-access databases.  DDR Holdings, LLC v. Hotels.com, L.P., 773 F.3d 1245, 1257 (Fed. Cir. 2014).  Further, the Federal Circuit found that the claims were not saved from abstraction merely because they required a specific database structure that was more specific than a generic computer.  Also, the Federal Circuit stated that the claims did not recite any improvement to the way in which databases store or organize information.

Under step two of Alice, the Federal Circuit also agreed with the district court that the asserted claims lacked an inventive concept.  BSG alleged that the “requirement that users are guided by summary comparison usage information or relative historical usage information” was an unconventional feature.  However, the Federal Circuit found that this language simply restated what was already determined to be an abstract idea.

Breaching a Duty of Disclosure to a Standards-Setting Organization May Constitute Implied Waiver Where the Breach is Egregious or Results in an Unfair Benefit

In Core Wireless Licensing v. Apple Inc., Appeal No. 2017-2102, the Federal Circuit held that breaching a duty of disclosure to a standards-setting organization may constitute implied waiver and render a patent unenforceable if the proposed standard covers a technology claimed in a patent, and the patentee’s misconduct is egregious or results in an unfair benefit.  

Core Wireless sued Apple for patent infringement.  Apple argued that one of the asserted patents, the ’151 patent, was unenforceable due to implied waiver.  The ’151 patent is directed to a novel synchronization feature in telecommunications.  The inventor of the yet-unfiled ’151 patent prepared an invention report which included a proposal to the European Telecommunications Standards Institute (“ETSI”) to modify a standard to use the synchronization feature disclosed in the report.  Contemporaneous with submitting the proposal to the ETSI, the patent applicant filed a Finnish patent application, to which the ’151 patent would claim priority, covering the synchronization feature.  The Finnish patent application was not disclosed until four years later, by which time the proposal had been rejected by ETSI. 

Apple argued that the patent applicant, of whom Core Wireless was the successor-in-interest, breached its obligation to disclose the Finnish patent application to ETSI, and thereby waived its right to enforce the ’151 patent.  The district court rejected Apple’s arguments, finding that there was no duty to disclose the Finnish patent application because the proposal had been rejected, and because the claims in the application had not been finalized by grant.  The district court thus found the ’151 patent not unenforceable, and Apple appealed to the Federal Circuit.

The Federal Circuit vacated the district court’s decision and remanded the case.  A participant in a standards-setting organization may waive its right to assert infringement claims against products that practice the standard.  Specifically, implied waiver can be shown where a patentee breaches a duty of disclosure to the standards-setting organization. Implied waiver should only be applied where the misconduct results in an “unfair benefit,” or in cases of egregious misconduct. The Federal Circuit found the district court’s determination that the patent applicant had no obligation to disclose the patent application to the ETSI was unsupported by evidence—the obligation of disclosure was not dependent on the proposal being accepted, or the claims in the application being granted.  The Federal Circuit thus vacated the district court’s holding of no unenforceability and remanded for the district court to consider whether the patent applicant benefited from the failure to disclose or whether the applicant’s conduct was sufficiently egregious to justify a finding of implied waiver. 

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.

© Knobbe Martens | Attorney Advertising

Written by:

Knobbe Martens

Knobbe Martens 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.