FERC Issues Penalty Assessment in Vitol CAISO Market Manipulation Proceeding

Blank Rome LLP
Contact

Blank Rome LLP

The Federal Energy Regulatory Commission issued an Order Assessing Civil Penalties, imposing approximately $1.5 million in civil penalties on Vitol Inc. and one million dollars in penalties on a Vitol trader. In a departure from prior cases, the Commission assessed penalties well below Enforcement Staff’s recommended six-million-dollar penalty for the company, in light of the individual trader’s significant involvement in the alleged scheme. The next step for Respondents wishing to challenge the Order will be de novo review in federal district court.

On October 25, 2019, the Federal Energy Regulatory Commission (“FERC” or “Commission”) issued an Order Assessing Civil Penalties (“Order”), imposing civil penalties of $1,515,738 against Vitol Inc. (“Vitol”) and one million dollars against Federico Corteggiano, a Vitol trader, in connection with an alleged market manipulation scheme in the California Independent System Operator Corporation’s (“CAISO”) markets.[1] Additionally, the Commission ordered Vitol to disgorge unjust profits, plus interest, of $1,227,143.

As we have previously discussed, the Commission began this proceeding by issuing an Order to Show Cause and Notice of Proposed Penalty to Respondents on July 10, 2019. In that order, the Commission directed Vitol and Corteggiano to show cause why they should not be assessed civil penalties of six million dollars and $800,000, respectively, and why Vitol should not be required to disgorge unjust profits of $1,227,143, plus interest. Respondents elected to have the Commission assess an immediate penalty if it finds a violation and then proceed with de novo review before a federal district court.

In the instant Order, the Commission found that Vitol and Corteggiano (collectively, “Respondents”) violated the anti-manipulation prohibitions in the Federal Power Act (“FPA”) and FERC’s Anti-Manipulation Rule[2] through a cross-market scheme in which Respondents sold power at a loss in the CAISO wholesale electric market to avoid greater losses in Vitol’s positions in a separate financial product—congestion revenue rights (“CRRs”).[3] 

Violation of Anti-Manipulation Rule

Generally, a violation of the Anti-Manipulation Rule consists of the following elements: (1) a fraud, scheme, or artifice;[4] (2) with the requisite scienter; (3) in connection with the purchase, sale, or transmission of electric energy subject to FERC’s jurisdiction.

With respect to fraud, the Commission concluded that Respondents engaged in a fraudulent device, scheme, or artifice to defraud CAISO and its market participants by submitting physical import bids at the Cascade intertie in order to eliminate congestion at Cragview, resulting in a lower Cragview LMP and preventing losses in Respondents’ CRRs sourced at Cragview. The Commission noted that it has on several occasions found fraud in the context of cross-market schemes.[5] Here, the Commission cited the following evidence as indicia of such a scheme:

  1. The timing and pattern of Respondent’s physical import transactions at Cragview during the relevant period, which diverged significantly from Respondents’ normal trading activity and correlated with dates on which their CRRs would be affected;
  2. Respondents’ indifference to the profitability of their physical imports at Cragview;
  3. Communications, testimony, and evidence substantiating the existence of a scheme to defraud; and
  4. Respondents’ inability to offer credible and relevant explanations for the imports.

The Commission reiterated that an entity “need not violate a tariff, rule, or regulation to commit fraud.”[6] The Commission disagreed that Office of Enforcement (“OE”) Staff was required to provide evidence of material misrepresentations, omissions, or employment of deceptive devices (such as wash trades). According to the Commission, simply engaging in trades undertaken for a manipulative purpose injected false information into the market and constituted a fraud or deceit. The Commission was also unpersuaded by Respondents’ arguments that no manipulation violation occurred because CAISO is a flawed market, or because the transactions at issue were “open market” transactions.

Regarding the second element, the Commission concluded, based on contemporaneous communications, testimony, and trade data, that Respondents acted with the requisite scienter. The Commission again pointed to Respondents’ divergence from normal trading activity and indifference to profitability of the physical trades as indicia of manipulative intent. The Commission additionally found that Corteggiano had the requisite knowledge and understanding of the market to execute the scheme. Although Respondents highlighted the fact that Corteggiano consulted with Vitol’s in-house counsel and compliance advisors on the transactions, the Commission emphasized that Corteggiano did not fully disclose material information regarding the transactions or follow legal counsel’s guidance.

Furthermore, the Commission disagreed that it is required to show there was no lawful purpose for the transactions, noting that “a manipulative purpose, even if mixed with some non-manipulative purpose, satisfies the scienter requirement.”[7]

Finally, the Commission found that it has jurisdiction over the applicable transactions—i.e., day-ahead physical offers and CRR positions under CAISO’s FERC-approved Tariff.

Penalty Assessment

The Commission is authorized to assess civil penalties of up to one million dollars per day,[8] per violation for violations of Part II of the FPA, including violations of the anti-manipulation prohibition.[9] In determining the penalty, the Commission must consider “the seriousness of the violation and the efforts of such person to remedy the violation in a timely manner.”[10]

For violations committed by companies, the Commission is generally guided by its Penalty Guidelines, under which it establishes a penalty range based on (1) a Base Penalty amount (based on factors relating to the seriousness of the violation, including harm caused); and (2) several culpability factors, such as efforts to remedy violations, that adjust the Base Penalty amount. The Commission evaluates the specific facts of the case to determine the appropriate penalty within (or, as in this case, outside of) this range that it will ultimately assess.

For violations by individuals, the Commission considers the following factors: (1) seriousness of the violation; (2) commitment to compliance; (3) self-reporting; (4) cooperation; and (5) reliance on OE Staff guidance.

The Commission’s adoption of a $1,515,738 penalty for Vitol fell significantly below OE Staff’s recommended six-million-dollar penalty. According to the Commission, the penalty range under the Penalty Guidelines was $2,515,738 to $5,031,476, derived based on the following considerations:

  • The seriousness of the violation: Specifically, the Commission indicated that Respondents caused $2,515,738 in market harm in the form of (a) $2,429,385 in reduced funding of CAISO’s CRR Balancing Account, and (b) $86,353 in losses suffered by the holders of CRR counter-flow positions; that Respondents’ manipulative trades operated as a fraud and deceit on the CAISO market and its participants; and that Respondents’ conduct was willful.
  • Aggravating and mitigating culpability factors: The Commission added points to Vitol’s culpability score due to the involvement of high-level personnel in the manipulative transaction; reduced points based on Vitol’s compliance program, but also identified certain shortfalls in the program;[11] and reduced one point for Vitol’s cooperation in the investigation.

However, the Commission decided to depart from the Penalty Guidelines. Although the Commission assessed a total civil penalty of $2,515,738 on Respondents (i.e., the bottom of the Penalty Guidelines range), the Commission reduced Vitol’s penalty to $1,515,738 to reflect the one-million-dollar penalty attributed to Corteggiano, whom the Commission noted was the primary actor involved in the alleged scheme. The Commission cited to Corteggiano’s role in devising the scheme, proposing it to other employees, facilitating its approval, benefiting CRRs booked to his account, withholding information from compliance personnel, as well as the fact that he engaged in similar behavior at a prior company investigated by FERC. Based on these facts, the Commission concluded that a “strict application of the Penalty Guidelines to Vitol’s conduct would, considering all of the facts and circumstances in this matter, be unfair and unreasonable and apportion too large a penalty to Vitol because it would not adequately account for conduct that was conceived of and primarily carried out by an individual trader.”[12] The Commission’s divergence from OE Staff’s recommendations and the Penalty Guidelines is a departure from its practice in prior manipulation cases.[13]

Meanwhile, in light of the “serious and intentional” nature of his conduct, the one-million-dollar penalty assessed on Corteggiano exceeded OE Staff’s recommended $800,000 penalty.


[1] Vitol Inc., Order Assessing Civil Penalties, 169 FERC ¶ 61,070 (2019).

[2] FPA § 222 (2012); 18 C.F.R. § 1c.2 (2019).

[3] Specifically, the Commission found Respondents intentionally engaged in fraudulent physical energy imports during the period October 28-November 1, 2013, at the Cascade intertie to relieve congestion at Cragview, which in turn lowered the Cragview locational marginal price (“LMP”) and economically benefitted Vitol’s CRRs sourced at that location. Order at P 34.

[4] Specifically, the Anti-Manipulation Rule prohibits “. . . any entity, directly or indirectly, in connection with the purchase or sale of electric energy or the purchase or sale of transmission services subject to the jurisdiction of the Commission,

(1) To use or employ any device, scheme, or artifice to defraud;

(2) To make any untrue statement of a material fact or to omit to state a material fact necessary in order to make the statements made, in the light of the circumstances under which they were made, not misleading; or

(3) To engage in any act, practice, or course of business that operates or would operate as a fraud or deceit upon any entity.”

18 C.F.R. § 1c.2.

[5] Order at P 60 (citing ETRACOM LLC, 155 FERC ¶ 61,284 (2016); Barclays Bank PLC, 144 FERC ¶ 61,041 (2013)).

[7] Id. at P 183 (quoting Barclays, 144 FERC ¶ 61,041 at P 70).

[8] Adjusted for inflation, this number is currently over $1.2 million per day.

[9] 16 U.S.C. § 825o-1(b).

[10] Order at P 189 (citing 16 U.S.C. § 825o1-(b)).

[11] For example, the Commission noted that the compliance program provided insufficient training for compliance officers to identify problematic transactions and lacked procedural or substantive guidelines to assist compliance in determining whether cross-market trades should be allowed. Id. at P 220.

[13] For example, in all but one electric market manipulation cases in the last six years, the Commission adopted OE Staff’s civil penalty recommendations based on the Penalty Guidelines or the Commission’s Revised Policy Statement on Enforcement. See ETRACOM, LLC, Order Assessing Civil Penalties, 155 FERC ¶ 61,284 (2016) (adopting OE Staff’s recommended $2.4 million civil penalty for the company, and $100,000 penalty for individual); Coaltrain Energy, L.P., Order Assessing Civil Penalties, 155 FERC ¶ 61,204 (2016) (adopting OE Staff’s recommended $26 million penalty assessment against company, and five-million-dollar, one-million-dollar, and $500,000 penalties against individuals); Maxim Power Corp., Order Assessing Civil Penalties, 151 FERC ¶ 61,094 (2015) (adopting OE Staff’s recommended five-million-dollar civil penalty for companies, and $50,000 for individual); City Power Marketing, LLC, Order Assessing Civil Penalties, 152 FERC ¶ 61,012 (2015) (adopting OE Staff’s recommended $14 million penalty against company, and one-million-dollar penalty for individual); Powhatan Energy Fund, LLC, Order Assessing Civil Penalties, 151 FERC ¶ 61,179 (2015) (adopting OE Staff’s recommended penalties of $16.8 million, $10.08 million, and $1.92 million for companies, and one million dollars for individual); Barclays Bank PLC, Order Assessing Civil Penalties, 144 FERC ¶ 61,041 (2013) (adopting OE Staff’s recommended $435 million civil penalty against company, and penalties of one million dollars and $15 million for individual traders). In the one case where the Commission diverged from OE Staff’s recommendation, it adopted an increased penalty assessment. Lincoln Paper & Tissue, LLC, Order Assessing Civil Penalty, 144 FERC ¶ 61,162 (2013) (assessing a civil penalty of five million dollars—$600,000 higher than OE Staff’s proposal—due to denial of cooperation credit).

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.

© Blank Rome LLP | Attorney Advertising

Written by:

Blank Rome LLP
Contact
more
less

Blank Rome 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.