Important Legislative and Regulatory Changes Impacting the Commercialization of Cannabis, Hemp, and CBD

by Wilson Sonsini Goodrich & Rosati

A number of important changes have occurred in the cannabis, hemp, and cannabidiol (CBD) spaces. This alert presents a snapshot of significant developments and selected future predictions.

1) The U.S. Food and Drug Administration (FDA) approved the first CBD oil drug

Recently, the FDA approved GW Pharmaceutical's oral CBD based drug, Epidiolex, to treat severe forms of epilepsy.1 In its press release, the FDA notes: "CBD is a chemical component of the Cannabis sativa plant, more commonly known as marijuana. However, CBD does not cause intoxication or euphoria (the "high") that comes from tetrahydrocannabinol (THC)."2 Epidiolex's effectiveness was studied in three randomized, double-blind, placebo-controlled clinical trials involving 516 patients, and was shown to be effective in reducing the frequency of seizures when compared with a placebo.3

The approval is significant for many reasons, including that it represents the first time the U.S. federal government has acknowledged there are medicinal benefits to be obtained from substances derived from a cannabis plant.

2) The Drug Enforcement Administration (DEA) rescheduled some, but not all, CBD derived from cannabis

Before Epidiolex's approval, CBD was classified by the DEA under the Controlled Substances Act, and subsequent amendments, as a schedule I substance4—meaning that CBD had "no medically accepted use." The FDA's approval of Epidiolex meant that, by definition, all CBD could no longer be classified as having "no medically accepted use."

Accordingly, the DEA reclassified some CBD from a schedule I to a schedule V substance.5 Schedule V substances are considered to have the lowest abuse potential and a low potential for psychological or physical dependence.6

Importantly, only small amounts of cannabis derived CBD are classified as schedule V. As recited in the DEA's Federal Register Notice: "Specifically, this order places FDA-approved drugs that contain CBD derived from cannabis and no more than 0.1 percent tetrahydrocannabinols in schedule V."7

3) The Farm Bill recognizes significant legal differences between CBD derived from hemp and CBD derived from cannabis

Congress and the President recently enacted the Agriculture Improvement Act of 2018, or the Farm Bill.8 The Farm Bill has several important provisions. For purposes of this section, the two most important provisions are as follows:

First, the Farm Bill defines hemp to mean "the plant Cannabis sativa L. and any part of that plant, including the seeds thereof and all derivatives, extracts, cannabinoids, isomers, acids, salts, and salts of isomers, whether growing or not, with a delta-9 tetrahydrocannabinol concentration of not more than 0.3 percent on a dry weight basis."9 Second, the Farm Bill amends the Controlled Substances Act to state that "marihuana" [sic] does not include "hemp" and excludes from schedule I controlled substances "tetrahydrocannabinols in hemp." 10

Because hemp and its extracts—which would include CBD—are not included in "marihuana" under the Controlled Substances Act, the Farm Bill provides for: the broad cultivation of hemp, the transfer of hemp-derived products in interstate commerce, and the sale of these; so long as all of the above are done in a manner consistent with all federal and state laws.

4) Commercialization of Hemp in the United States

Because of the Farm Bill's hemp provisions, we expect the financial structure of the hemp industry to differentiate from the financial structure of the cannabis industry (e.g., all cash transactions). We expect hemp to pivot towards conventional banking and financial services. We also expect investments and capital inputs to increase in the hemp industry.

5) The FDA's approval of the first drug containing CBD, and the hemp provisions in the Farm Bill, may open the door for more medical research on hemp derived CBD

In announcing Epidiolex's approval, FDA Commissioner Scott Gottlieb stated: "We'll continue to support rigorous scientific research on the potential medical uses of marijuana-derived products and work with product developers who are interested in bringing patients safe and effective, high quality products."11 Gottlieb was explicitly signaling that the FDA is willing to work with pharmaceutical companies to bring cannabis derived products to market.

Enactment of the Farm Bill, coupled with the FDA's willingness to consider drugs containing CBD, could open the door to an increase in FDA regulated research and approvals of drugs containing hemp derived CBD.

6) Placing CBD in foods and dietary supplements

In a recent statement, FDA Commissioner Scott Gottlieb stated in part:

Additionally, it's unlawful under the FD&C Act to introduce food containing added CBD or THC into interstate commerce, or to market CBD or THC products as, or in, dietary supplements, regardless of whether the substances are hemp-derived. This is because both CBD and THC are active ingredients in FDA-approved drugs and were the subject of substantial clinical investigations before they were marketed as foods or dietary supplements. Under the FD&C Act, it's illegal to introduce drug ingredients like these into the food supply, or to market them as dietary supplements. This is a requirement that we apply across the board to food products that contain substances that are active ingredients in any drug.12

Thus, the FDA will likely continue to take enforcement actions against companies selling dietary supplements and foods that contain CBD, regardless of whether the CBD ingredient was derived from hemp or cannabis. Importantly, enforcement action will likely increase if drug claims are included in promotional messaging and labeling.

7) A tension, and uneasy truce, exists between federal and state law regarding cannabis (and CBD derived from cannabis)

The majority of states currently allow for the possession and consumption of cannabis and/or cannabis derived products (for recreational purposes), for medical uses, or in some limited capacity (e.g., for high CBD, low TCH oil).13

Thus, the laws in each state can be different, and state laws often conflict with federal law (e.g., the Controlled Substances Act). A somewhat uneasy truce currently exists, after e.g., the Department of Justice, or DOJ, issued its enforcement position in an August 29, 2013, memorandum.14 This memorandum indicates, in part, that the DOJ will utilize enforcement resources based on specifically enumerated priorities, and for the most part, rely on state and local authorities to regulate "small amounts of marijuana for personal use on private property."15

8) Physicians' "recommendations" for cannabis and cannabis derived substances

The FDA does not regulate the practice of medicine by physicians. Nevertheless, most cannabis and cannabis derived substances—as schedule I substances—are illegal at the federal level under the Controlled Substances Act and other federal laws. Thus, any state law that allows physicians to "prescribe" cannabis could conflict with federal law. And such a conflicting state law could be found to be invalid under the Supremacy Clause of the Constitution. Therefore, many states have addressed this dilemma by implementing laws built around the Ninth Circuit's Conant v. Walters case.16,17

In Conant, the court held that the federal government could not revoke a physician's license to prescribe a controlled substance solely because the physician "recommended" the use of medical marijuana to a patient. The court also held that the federal government could not conduct an investigation that could lead to revocation where the basis for the government's action is solely the physician's professional "recommendation" of the use of medical marijuana.18 The court reasoned, in part, that the physician's recommendation was an expression that was protected by the free speech provisions of the First Amendment, and that the dispensing of information—or a "recommendation" concerning a controlled substance—is different than the dispensing of controlled substances.19

Thus, under many state laws, physicians will, if appropriate in their professional medical opinion, "recommend" rather than "prescribe" medical marijuana.

9) A patent land grab may occur in the cannabis, hemp, and CBD spaces

Historically, many companies and individuals have been hesitant to file patents for cannabis, and cannabis derived substances, for fear that doing so would make it easier for the federal government, and specifically the DEA and DOJ, to identify and target these companies and individuals. This may change given the ground swell of favorable public opinion, the FDA's approval of Epidiolex, the passage of the Farm Bill, and an influx of venture capital into cannabis- and hemp-related businesses.

In addition to utility patents, federal patent law20 allows for patent protection of invented or discovered and asexually reproduced plants (other than tuber propagated plants or plants found in an uncultivated state). The Farm Bill, among other things, also expands the Plant Variety Protection (PVP) Act to cover asexually reproduced varieties,21 creating the possibility of obtaining utility patents, plant patents, and PVP certificates as forms of intellectual property protection.

10) Cannabis, hemp, and CBD patents must still meet statutory requirements and, like other utility patents, can be challenged in the federal courts and the U.S. Patent and Trademark Office

Because CBD patents, including medical drug patents, may become more valuable and listed in the Orange Book,22 these patents may be challenged in federal district courts and in the U.S. Patent and Trademark Office. An example is U.S. Patent No. 9,066,920 (the '920 patent), owned by GW Pharma Limited and Otsuka Pharmaceutical Co., Ltd. The '920 patent contains 13 claims. Representative independent claim 1 recites:

A method of treating partial seizure comprising administering cannabidiol (CBD), to a patient wherein the CBD is present in an amount which provides a daily dose of at least 400 mg.

Claims 1-13 were challenged in an inter partes review, and claims 1 and 2 were found to be unpatentable.23,24 While it is noteworthy that claims 1-2 were shown to be unpatentable, it is equally noteworthy that claims 3-13 remained patentable.


Federal and state law on hemp, cannabis, and CBD continue to evolve in a fast-paced, and not-always-predictable, fashion. It is recommended that companies operating in these areas consult counsel early and often to understand and minimize the risk of running afoul of federal and state laws, and regulatory agencies.

1 "FDA approves first drug comprised of an active ingredient derived from marijuana to treat rare, severe forms of epilepsy," FDA Press Release; available at:
4 21 U.S.C. § 812(b)(1)(A)-(C).
5 83 Fed. Reg. 48950 (Sept. 28, 2018); available at:
6 21 U.S.C. § 812(b)(5)(A)-(C).
7 83 Fed. Reg. 48950 (Sept. 28, 2018); available at:
8 The Agriculture Improvement Act of 2018; available at:
9Id. at Section 297A(1).
10Id. at Section 12619.
11 "FDA approves first drug comprised of an active ingredient derived from marijuana to treat rare, severe forms of epilepsy," FDA Press Release; available at:
12 "Statement from FDA Commissioner Scott Gottlieb, M.D., on signing of the Agriculture Improvement Act and the agency's regulation of products containing cannabis and cannabis-derived compounds," FDA (Dec. 2018); available at
13See, e.g., "State Medical and Recreational Marijuana Laws Chart: Overview," Practical Law Labor & Employment, Westlaw (2019).
14See, e.g., James M. Cole, "Guidance Regarding Marijuana Enforcement," DOJ, (Aug. 29, 2013); available at:
16Conant v. Waters, 309 F.3d 629 (9th Cir. 2002), cert denied.
17Conant, being a Ninth Circuit Case, does not apply to every state in the U.S. Nevertheless, many states have interpreted the U.S. Supreme Court's denial of certiorari as an indication that the Supreme Court agrees with the Ninth Circuit's holding.
19Id. at 629, 635-639.
20 35 U.S.C. §: 161. The statute states:
Whoever invents or discovers and asexually reproduces any distinct and new variety of plant, including cultivated sports, mutants, hybrids, and newly found seedlings, other than a tuber propagated plant or a plant found in an uncultivated state, may obtain a patent therefor, subject to the conditions and requirements of this title.
21See the Farm Bill, Section 10108. The Amendment recites:
(b) Right to Plant Variety Protection; Plant Varieties
"Protectable.—Section 42(a) of the Plant Variety Protection Act (7 U.S.C. 2402(a)) is amended by striking "or tuber propagated" and inserting, "tuber propagated, or asexually reproduced."
22 For example, Epidiolex has eight U.S. patents listed in the Orange Book, each with a listed expiration date in 2035. See
23 Under 35 U.S.C. § 103(a). See Final Written Decision, IPR2017-00503.

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.

© Wilson Sonsini Goodrich & Rosati | Attorney Advertising

Written by:

Wilson Sonsini Goodrich & Rosati

Wilson Sonsini Goodrich & Rosati 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.