New Types of Section 337 Investigations at the International Trade Commission

Foley & Lardner LLP

Most Section 337 investigations allege violations of intellectual property (“IP”) based rights involving patent, registered trademark, or registered copyright infringement (“statutory IP claims”). In such cases, the complainant must establish that a valid and enforceable U.S. patent, trademark, or copyright is being infringed by the importation into the U.S., the sale for importation, or the sale within the U.S. after importation of an accused article, and that a domestic industry exists or is in the process of being established.

In recent years, however, the ITC has seen a sharp increase in the number of Section 337 investigations alleging other types of claims. For example, in 2011, only three investigations alleged non-patent claims, but in 2016 and 2017 the numbers reached twenty and fifteen, respectively. The statutory language for Section 337 claims is broad and applies to any “unfair methods of competition and unfair acts in the importation of articles.” 19 USC 1337(a)(1)(A). Based on this language, complainants have asserted claims of trade secret misappropriation, antitrust violations, false advertising, breach of contract, and tortious interference with contractual relations. [1] Indeed, the language is broad enough to support other types claims that are as yet un-tested at the ITC, such as foreign bribery, use of forced labor, and other violations of international or U.S. law by competitors. For non-statutory IP claims, complainants must establish that the accused unfair methods or acts have the threat or effect of which is “to destroy or substantially injure an industry in the United States,” “to prevent the establishment of such an industry,” or “to restrain or monopolize trade and commerce in the United States.” 19 USC 1337(a)(1)(A).

This article discusses recent investigations with noteworthy non-statutory IP claims.

Theft of Trade Secrets Claims

Claims based on trade secret misappropriation have been on the rise since the Federal Circuit’s decision in TianRui Group Co. v. International Trade Commission, 661 F.3d 1322 (Fed. Cir. 2011). In that investigation, the complainant alleged that TianRui imported steel railway wheels made using trade secrets misappropriated from complainant’s licensee in China. Even though the misappropriation took place abroad, the Commission considered the conduct, found a Section 337 violation, and issued a 10-year exclusion order. The Federal Circuit affirmed, holding the Commission could consider extraterritorial conduct when necessary to protect a domestic industry because Section 337 addresses unfair methods of competition and unfair acts in the importation of accused articles.

The TianRui decision is noteworthy for several reasons. First, it reinforces that Section 337 may be the only means for litigating this type of foreign misconduct, given the inapplicability at the ITC of the presumption against extraterritoriality that applies to statutory claims in federal district court. Second, the decision confirms that relief under Section 337 is available even when the complainant no longer practices the trade secret domestically, as was the case there. Finally, the decision shows the scope of relief possible under Section 337. For a violation based on trade secret misappropriation, exclusion must be for a period of reasonable research and development or independent development. In the case of TianRui, the Commission found that period to be a decade.

Since TianRui, other complainants have successfully used the ITC to obtain relief for claims of foreign theft of trade secret. For example, in Certain Electric Fireplaces, Components Thereof, Manuals for Same, Certain Processes for Manufacturing or Relating to Same, and Certain Products Containing Same (No. 337-TA-826), a Florida-based home furnishing provider alleged that a former employee based in China stole trade secrets for its proprietary electric fireplaces. The trade secrets related to the manufacturing process and specifications, lists of component suppliers and customers, and prototype designs for the fireplaces. The former employee allegedly had access to the trade secrets and improperly disclosed them to his new company in China, which used the secrets to make similar electric fireplaces for sale in the U.S. The ITC instituted the investigation, in default found the former employee and his new company had violated Section 337 for trade secret theft, and issued a 5-year exclusion order.

In Certain Rubber Resins and Processes for Manufacturing Same (No. 337-TA-849), complainant SI Group alleged that respondent Sino Legend stole trade secrets for chemical compounds used in the manufacture of tires. Two SI Group employees with access to the trade secrets had left SI Group in China and joined Sino Legend in China. Soon after, Sino Legend began making and importing the chemical compounds from China into the United States. The Administrative Law Judge (“ALJ”) found a violation of Section 337 for theft of trade secrets and recommended a 10-year exclusion order. The Commission adopted the bulk of the ALJ’s findings, and Sino Legend appealed. The Federal Circuit summarily affirmed without responding to Sino Legend’s attempt to rehash TianRui or fault the ITC for not according comity to parallel Chinese proceedings.

The bases for the theft of trade secrets claims also have grown. In a recent Section 337 investigation, the complainant advanced a novel claim of theft of trade secrets based on computer hacking. In Certain Carbon and Alloy Steel Products (No. 337-TA-1002), complainant U.S. Steel alleged Chinese steel producers had imported steel products made using U.S. Steel trade secrets obtained through computer hacking. It is noteworthy that U.S. Steel alleged the perpetrator of the computer hacking was the Chinese government, which raises a slew of separate issues. The Chinese steel producers moved to dismiss the trade secret theft claim and sought a second review of the claim by the Commission. The claim survived both challenges. Even though U.S. Steel later withdrew the claim, the fact that it survived these early challenges shows its viability. With increasing cybersecurity breaches, we expect to see more of these types of claims.

We also expect to see more theft of trade secrets claims with the enactment of the Defend Trade Secrets Act of 2016. That Act provided a uniform standard to be applied in federal court for theft of trade secrets claims, whereas previously ITC complainants relied on various state laws.

Antitrust Claims

Section 337 claims based on antitrust violations are also on the rise. In Carbon and Alloy Steel Products, U.S. Steel also alleged that the Chinese steel producers had conspired to fix prices too low in violation of Section 1 of the Sherman Act. This was the first time in nearly forty years that a complainant had raised an antitrust claim in a Section 337 investigation. Respondents moved to terminate because U.S. Steel did not plead an antitrust injury, as is required for standing in federal district court. In particular, U.S. Steel alleged the price-fixing conspiracy was to set prices too low however, U.S. Steel did not allege predatory pricing. U.S. Steel argued Section 337 does not require pleading of an antitrust injury that would be required in a district court complaint—all that is required is an “unfair method of competition” or other “unfair act” in the importation of articles and an injury or threat of injury resulting from that act. While the Commission terminated the claim in a final determination, central to the Commission’s determination was the recognition that “the Commission has been guided by the express Congressional limitations on federal law in other substantive areas when determining the scope of unfair acts” under Section 337. Carbon Steel and Alloy Products, Comm’n Op. (Majority) at 12. This ruling is unlikely to have a broad impact on future antitrust claims, as U.S. Steel’s price-fixing claim was atypical.

Shortly after terminating the antitrust claim in Carbon and Alloy Steel Products, the Commission instituted another antitrust-based Section 337 investigation. In Certain Programmable Logic Controllers (No. 337-TA-1105), the complainant alleged that it had suffered substantial injury from respondent’s alleged (i) hub-and-spoke conspiracy designed to prevent resellers, like the complainant, from purchasing and reselling respondent’s imported programmable logic controllers (“PLCs”) and (ii) a resale price-fixing conspiracy. The complainant alleged it suffered antitrust injury stemming from these violations of the Sherman Act. The antitrust claim survived a significant pre-institution challenge by the respondent attacking the sufficiency of the complaint to plead any unfair act in the importation of products.

Lanham Act Claims

The ITC is also seeing an increase in Section 337 claims for violations of the Lanham Act. One area of focus has been false advertising claims relating to drug and medical device cases. In Certain Potassium Chloride Powder Products (No. 337-TA-1013), a drug manufacturer successfully advanced a novel claim of false advertising of an unapproved drug. [2] The Commission instituted the investigation, which was settled prior to the hearing. The complainant drug manufacturer sold the only FDA-approved version of the drug, but respondents held the majority of the market. The complainant alleged this disparity was due to respondents’ unfair competition of false and misleading advertising. The complainant alleged that respondents improperly imported a potassium chloride powder product as a dietary supplement but labeled the product as a drug to mislead consumers into believing the product was FDA approved, or the same as complainant’s FDA-approved version.

This framing of the unfair act in terms of false advertising has proven successful in other cases. In Certain Periodontal Laser Devices (No. 337-TA-1070) and Certain Clidinium Bromide & Products Containing Same (No. 337-TA-1109), the Commission instituted investigations in which the complaint similarly alleged unfair acts of false advertising relating to unapproved drugs or medical devices.

But in one recent case, the Commission denied institution. In Certain Synthetically Produced, Predominantly EPA Omega-3 Products, the complainant filed a complaint alleging unfair acts of false advertising relating to Omega-3 products. Unlike the complaints discussed above, this complaint focused heavily on the issue of whether the accused products were dietary supplements or unapproved drugs. As a result, the case drew briefing from parties and non-parties as to whether the ITC had jurisdiction over the claim, or whether it fell within the FDA’s purview. In an unusual move, the FDA weighed in asking the ITC to deny institution. In the end, the ITC did just that. The ITC’s decision not to institute is now on appeal at the Federal Circuit.

In another novel claim from Carbon and Alloy Steel Products, U.S. Steel alleged the Chinese steel producers evaded U.S. antidumping and countervailing duty (“CVD”) orders on Chinese steel imports by submitting false documents and transshipping products through other countries to disguise the steel’s country of origin from U.S. Customs. U.S. Steel framed the claim as a traditional Lanham Act False Designation of Origin (“FDO”) Claim under Section 337 rather than seeking to enforce the antidumping and CVD orders. This is important because the remedy under Section 337 is an exclusion order, whereas a circumvention proceeding before Customs and Border Patrol and the Department of Commerce would result in a ruling that the importer owed duties (and perhaps fines and penalties) on the imported goods. The ALJ dismissed the FDO claim because U.S. Steel’s complaint failed to allege specific acts of importation. This narrow ruling was directed to the sufficiency of the allegations in the complaint, not the viability of such a claim. If the Commission determines in a future investigation that such claims are within the scope of Section 337, this approach could be a powerful weapon for U.S. industries to enforce anti-dumping and countervailing duty orders.

Contract Claims

The Commission has not directly addressed whether a contract claim is an unfair act or unfair method of competition under Section 337. But it has instituted an investigation with two contract claims. In Electric Fireplaces (No. 337-TA-826) discussed above, the home furnishing provider alleged that its former employee had breached a stockholder agreement with non-compete, non-solicitation, and confidentiality provisions. The provider also alleged that the former employee’s new company had tortiously interfered in contractual relations with customers. The ALJ found the respondents in default and ruled against them on the contract claims. The Commission reversed. By that time, the non-compete and non-solicitation provisions of the stockholder agreement had expired. Because the Commission can grant only prospective relief, it found no violation of Section 337 on those grounds. It also found the complaint had omitted any factual allegations concerning the particular confidential information allegedly disclosed, so it found no violation of Section 337 on that basis. The Commission did not reach the issue of whether the contract claims were within the scope of Section 337.


The number of non-statutory IP Section 337 claims at the ITC is on the rise. Complainants are recognizing that the powerful remedies of Section 337 make the ITC a favorable forum for IP and non-IP claims alike.

[1] Complainants have also asserted violation of state-law Uniform Deceptive Trade Practices Act, common law trademark infringement, and common law trade dress infringement, among other claims.

[2] The authors’ firm, Foley & Lardner LLP, represented the complainants in this investigation.

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.

© Foley & Lardner LLP | Attorney Advertising

Written by:

Foley & Lardner LLP

Foley & Lardner LLP on:

Readers' Choice 2017
Reporters on Deadline

Related Case Law

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide

JD Supra Privacy Policy

Updated: May 25, 2018:

JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.

This Privacy Policy describes how JD Supra, LLC ("JD Supra" or "we," "us," or "our") collects, uses and shares personal data collected from visitors to our website (located at (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.