Global Merger Control Update - May 2017

Jones Day

This is the quarterly Jones Day Global Merger Control Update, which will discuss recent developments in existing regimes and the emergence of new merger control regimes worldwide.

In recent years, there has been a surge in merger control enforcement around the world, beyond the major jurisdictions. There are currently over 110 jurisdictions with merger control regimes. Some are more active than others, but all must be taken into consideration when assessing the antitrust risks of a cross-border M&A transaction.

In this issue, we discuss recent key changes to the existing regimes in Austria, Chile, Germany, Hungary, India, and Ukraine. Although the changes are generally steps in the right direction, various provisions also result in subjecting international transactions to national merger control regimes that have little to no effect on their national markets. Nevertheless, not filing in such cases would amount to a breach of the stand-still obligation.

Also featured in this issue is the entry into force of the Philippines's new regime.


Germany and Austria Add a Transaction-Value Based Threshold

Germany. The new German law introduces a transaction-value based threshold of €400 million (approx. US$425 million). This change attempts to close a perceived enforcement gap, whereby certain mergers of considerable economic importance are not captured by the current thresholds, which are exclusively based on revenues. This gap is perceived to exist, in particular, in pharmaceutical and IT-related cases.

If the parties meet the combined worldwide turnover threshold (>€500 million, approx. US$531 million), and one party meets the domestic turnover threshold (>€25 million, approx. US$26 million), but neither the target nor any other party meets the second domestic turnover threshold (>€5 million, approx. US$5.3 million), a transaction is nevertheless notifiable, if:

(i) The transaction value exceeds €400 million (approx. US$425 million), and

(ii) The target has significant activities in Germany.

The transaction value includes the purchase price (including all assets and other monetary payments that the seller receives from the acquirer in connection with the transaction) and the value of any liabilities of the seller assumed by the purchaser. In complex M&A transactions, the calculation of that value may not be straightforward, for example, in purchase agreements involving "earn out-clauses," whereby a portion of the purchase price is made conditional upon the target's future performance.

According to an explanatory memorandum, whether a target is "active" in Germany is to be established based on the location of the target's customers—more specifically, the location of the designated use of the products. According to this condition, a target would be "active" in Germany where, for example, users in Germany would benefit themselves from the services offered by the target. More importantly, it is expressly stated that being "active" in Germany does not require achieving any revenues in Germany.

The explanatory memorandum does not establish how to determine whether the target's activity in Germany is "significant." The criteria to be taken into consideration include the sector or the maturity of the market concerned. Guidance is provided via specific examples. The condition would be met where, for example, the target markets a free software product, but the product is targeted at all consumers and used by more than 1 million users in Germany. On the other hand, where the target achieves considerable turnover worldwide but not in Germany, the old turnover-based threshold should apply.

The changes will enter into force in the coming weeks.

Austria. Similarly, effective as of November 1, 2017, Austria's amendments introduce a €200 million transaction-value based threshold. In addition to the current thresholds, which remain in place, a transaction will also be reportable if the following four cumulative conditions are fulfilled:

(i) Combined worldwide turnover of the undertakings exceeds €300 million (approx. US$318 million);

(ii) Combined Austrian turnover of the undertakings exceeds €15 million (approx. US$16 million);

(iii) The "value of consideration" for the transaction exceeds €200 million (approx. US$212 million); and

(iv) The target has significant activities in Austria.

Regarding the interpretation of thresholds (iii) and (iv), similar considerations as for Germany (below) apply. It is also expected that the authority will issue guidelines to clarify its interpretation of the new threshold.

Chile Begins Mandatory Merger Control Regime

Chile passed an important amendment to its merger control regime, which is inspired by regimes in force in other jurisdictions, in particular the European Union.

As of June 1, 2017, a mandatory prenotification regime has replaced the prior, voluntary regime. In addition, new filing thresholds have been adopted:

(i) Combined aggregate net sales of the parties (acquirer and target in an acquisition scenario) in Hungary exceeds Ft15 billion (approx. €48.3 million or US$53.5 million) and

(ii) Aggregate net sales of each of at least two of the groups of undertakings concerned (acquirer and target in an acquisition scenario) in Hungary exceeds Ft1 billion (approx. €3.1 million or US$3.5 million); or

(iii) Combined aggregate net sales of the parties (acquirer and target in an acquisition scenario) in Hungary exceed Ft5 billion (approx. €16.2 million or US$17.5 million), and the transaction may significantly lessen competition on the relevant market.

India Increases Merger Control Thresholds

The Indian Ministry of Corporate Affairs amended its merger control regime in March 2016. Most importantly, the applicable merger control thresholds increased:

(i) Value of assets in India exceeding ₹20 billion (approx. US$310 million, €291 million) of the target or the acquirer (not the acquirer group, only the acquiring legal entity and its subsidiaries), or both; or

(ii) Indian sales exceeding ₹60 billion (approx. US$930 million, €876 million) of the target or the acquirer (not the acquirer group, only the acquiring legal entity and its subsidiaries) or both; or

(iii) Value of assets worldwide exceeding US$1 billion (approx. €941 million), including at least ₹10 billion (approx. US$155 million, €145 million) in India, of the target or the acquirer (not the acquirer group, only the acquiring legal entity and its subsidiaries) or both; or

(iv) Sales exceeding US$3 billion (approx. €2.2 billion) worldwide, including at least ₹30 billion (approx. US$465 million, €437 million) in India, of the target or the acquirer (not the acquirer group, only the acquiring legal entity and its subsidiaries) or both; or

(v) Combined value of assets in India exceeding ₹80 billion (approx. US$1.2 billion, €1.2 billion) of the target and the acquirer group; or

(vi) Combined Indian sales exceeding ₹240 billion (approx. US$3.7 billion, €3.5 billion) of the target and the acquirer group; or

(vii) Combined value of assets worldwide exceeding US$4 billion (approx. €3.8 billion), including at least ₹10 billion (approx. US$155 million, €145 million) in India, of the target and the acquirer group; or

(viii) Combined sales worldwide exceeding US$12 billion (approx. €11.3 billion), including at least ₹30 billion (approx. US$465 million, €437 million) in India, of the target and the acquirer group;

(ix) Unless the value of the target's Indian assets (including subsidiaries) does not exceed ₹3.5 billion (approx. US$54 million, €51 million); or the target's Indian sales (including subsidiaries) do not exceed ₹10 billion (approx. US$155 million, €145 million).

In addition, the Ministry extended the Small Target Exemption [item (ix) above] until March 4, 2021. In March 2017, the Ministry expanded the scope of the Small Target Exemption to include transactions structured as mergers or amalgamations (previously, only acquisitions were covered).

The same amendment also clarifies that for purposes of the acquisition of a business, division or portion of an enterprise, only the assets and sales generated by that business are to be considered for assessing whether the filing thresholds are met. These changes appear to be inspired by the EU merger control regime.

Lastly, the Ministry extended a previous amendment, which defines "group" for the purposes of the above thresholds. Two companies are to be considered part of the same group where they are in a position to (i) exercise 50 percent or more voting rights in the other company; (ii) appoint more than 50 percent of the members of the board; or (iii) control the management or affairs of the other company.

The amended regime came into force in March 2016 and will apply until March 2021.

Ukraine Adjusts Merger Control Thresholds

In a welcome step, in the Ukrainian Parliament implemented a review of the existing merger control thresholds. The filing thresholds were increased, but remain low by international standards. Since May 2016, they are as follows:

(i) Combined parties' worldwide value of assets or turnover exceeding €30 million (approx. US$31.8 million) and the combined value of Ukrainian assets or turnover of at least two parties exceeding €4 million (approx. US$4.4 million) in the last financial year (increased from €1 million, approx. US$1.1 million); or

(ii) Ukrainian turnover or assets of target or of at least one "of the founders of a new entity" exceeding €8 million (approx. US$8.5 million) and worldwide turnover of at least one other party exceeding €150 million (approx. US$160 million) in the last financial year.

Nevertheless, various provisions continue to set the Ukrainian regime apart from most other international merger control regimes:

  • For purposes of the first threshold, the "parties" are to be interpreted as including the controlling seller that ceases to control the target post-transaction.
  • Also, for purposes of the second threshold, a recent statement by the Ukrainian authority [Antimonopoly Committee (AMC)] seems to indicate that the "target" is also to be interpreted as including the controlling seller.

Hence, given this wide interpretation of the thresholds, Ukraine remains a jurisdiction where filings are potentially required despite a very limited local nexus.

Other important amendments include the removal of the market share-based test (35 percent), and the introduction of a simplified 25-day fast-track procedure, applicable where:

  • Only one party is active in Ukraine, or
  • Combined market shares do not exceed 15 percent on overlapping markets, or 20 percent on vertically related markets.


Philippines Creates New Antitrust and Merger Control Regime

The Philippine Competition Act was signed into law in July 2015 and creates a comprehensive antitrust and merger control regime. Prior to this date, there was no such regime in the Philippines. Following a transitory period during which an interim merger control regime applied, the Philippine Competition Commission published the Implementing Rules and Regulations (IRR) of the Philippine Competition Act, which entered into force 15 days after their publication in June 2016.

Under the IRR, transactions are reportable where:

(i) The aggregate annual gross revenues in, into or from the Philippines, or value of the assets in the Philippines of the ultimate parent entity of at least one of the acquiring or acquired entities, including that of all entities that the ultimate parent entity controls, directly or indirectly, exceeds ₱1billion (approx. US$21.5 million, €19.0 million), and

(ii) The value of the transaction exceeds ₱1billion (approx. US$21.5 million, €19.0 million).

For purposes of this second threshold, the "value of transaction" is defined as follows:

With respect to a proposed merger or acquisition of assets in the Philippines, if either:

(i)  The aggregate value of the assets in the Philippines being acquired in the proposed transaction exceeds ₱1billion (approx. US$21.5 million, €19.0 million); or

(ii) The gross revenues generated in the Philippines by assets acquired in the Philippines exceed ₱1billion (approx. US$21.5 million, €19.0 million).

With respect to a proposed merger or acquisition of assets outside the Philippines, if:

(i) The aggregate value of the assets in the Philippines of the acquiring entity   (including affiliates) exceeds ₱1billion (approx. US$21.5 million, €19.0 million); and

(ii) The gross revenues generated in or into the Philippines by those assets acquired outside the Philippines exceed ₱1billion (approx. US$21.5 million, €19.0 million).

With respect to a proposed merger or acquisition of assets inside and outside the Philippines, if:

(i) The aggregate value of the assets in the Philippines of the acquiring entity (including affiliates) exceeds ₱1billion (approx. US$21.5 million, €19.0 million); and

(ii) The aggregate gross revenues generated in or into the Philippines by assets acquired in the Philippines and any assets acquired outside the Philippines collectively exceed ₱1billion (approx. US$21.5 million, €19.0 million).

After submission of the notification, the Commission has 15 days to determine whether the notification is complete, after which the Phase I review period of 30 days begins. In case of a Phase II investigation, the Commission has another 60 days for its review. Parties are barred from closing the transaction during the Phase I or Phase II review.

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.

© Jones Day | Attorney Advertising

Written by:

Jones Day

Jones Day 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 (our "Website") who view only publicly-available content as well as subscribers to our services (such as our email digests or author tools)(our "Services"). By using our Website and registering for one of our Services, you are agreeing to the terms of this Privacy Policy.

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

Collection of Information

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

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

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

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

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

How do we use this information?

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

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

How is your information shared?

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

How We Protect Your Information

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

Children's Information

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

Links to Other Websites

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

Information for EU and Swiss Residents

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

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

You can make a request to exercise any of these rights by emailing us at or by writing to us at:

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

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

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

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

California Privacy Rights

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

You can make a request for this information by emailing us at or by writing to us at:

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

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

Access/Correct/Update/Delete Personal Information

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

Changes in Our Privacy Policy

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

Contacting JD Supra

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

JD Supra Cookie Guide

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

How We Use Cookies and Other Tracking Technologies

We use cookies and other tracking technologies to:

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

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

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

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

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

  • HubSpot - For more information about HubSpot cookies, please visit
  • New Relic - For more information on New Relic cookies, please visit
  • Google Analytics - For more information on Google Analytics cookies, visit To opt-out of being tracked by Google Analytics across all websites visit This will allow you to download and install a Google Analytics cookie-free web browser.

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

Controlling and Deleting Cookies

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

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

Updates to This Policy

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

Contacting JD Supra

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

- hide

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