October 2019 Independent Contractor Misclassification and Compliance News Update

Locke Lord LLP

Last month saw large settlements and yet another new lawsuit against companies that have an independent contractor business model, but also success by such companies in obtaining a favorable jury verdict in an IC misclassification lawsuit and compelling arbitration of a lawsuit  and thereby avoiding a class action alleging misclassification of employees as independent contractors. These cases highlight the importance of two objectives:  enhancing compliance with IC laws that can lead to favorable resolutions of legal challenges (whether they are brought by class action lawyers or by regulatory or administrative agencies) and minimizing class actions by effective use of arbitration provisions with class action waivers.

More and more businesses seeking to elevate their level of IC compliance are using a process such as IC Diagnostics™ to minimize their exposure to class action lawsuits and maximize their likelihood of success if and when they are subjected to a lawsuit or regulatory or administrative review by a state or federal agency alleging IC misclassification.  This is accomplished by restructuring, re-documenting, and re-implementing IC relationships in a customized and sustainable manner consistent with a company’s business strategy and objectives.

One of the many components to a comprehensive solution-based approach to IC misclassification challenges is an effective arbitration agreement with a class and collective action waiver, consistent with the constantly evolving federal and state law in this area. Many companies are reviewing their arbitration agreements in view of new court decisions and laws affecting the enforceability of such agreements, especially provisions with class action waivers, and trying to make them as bulletproof as possible to the types of arguments that plaintiffs’ class action lawyers have been resorting to lately to challenge their validity.  In our article entitled “How to Effectively Draft Arbitration Clauses with Class Action Waivers in Independent Contractor Agreements,” which we republished in a blog post last year, we provided businesses with some of the tips we use to counteract such attacks and promote enforceability.

In the Courts (6 items)

NEW INSTACART INDEPENDENT CONTRACTOR MISCLASSIFICATION LAWSUIT FILED IN ILLINOIS.  Personal shoppers, drivers, and delivery persons have filed a proposed class and collective action lawsuit in Illinois federal court alleging wage and hour violations of the Fair Labor Standards Act and Illinois state wage laws due to their alleged misclassification as independent contractors and not employees.  Maplebear Inc. d/b/a Instacart is described in the complaint as a grocery shopping and delivery services company whose workers shop for groceries from various stores such as Safeway, Whole Foods, Trader Joe’s and Costco, and deliver them to Instacart customers within one or two hours. The plaintiffs are dispatched through a mobile phone app to shop, purchase and deliver groceries to customers at their homes and businesses. In support of their misclassification claim, the shoppers allege, among other things, that “Instacart controlled the ‘when,’ ‘where’ and ‘how’ of [their] work;” that the work performed was within the usual course of Instacart’s business of grocery delivery; and that the plaintiffs were not independently engaged in grocery delivery outside of their work for Instacart.  Additionally, the plaintiffs asserted that Instacart generated work orders for them; controlled their wages; enforced behavioral codes of conduct; directed precisely when and where they were to collect and deliver groceries to Instacart customers; expected them to hold themselves out to customers as Instacart employees by wearing lanyards with the company logo; told the plaintiffs how they were to interact with customers; had the right to terminate the plaintiffs’ relationships with Instacart; trained and directed the plaintiffs on how to evaluate and select fruits and vegetable; required them to accept every job that it sent to the plaintiffs’ smartphones within a set period of time or else be subject to financial repercussions; and monitored and managed their job performance “down to the minute.” O’Shea v. Maplebear Inc. d/b/a Instacart, No. 1:19-cv-06994 (N.D. Ill. Oct. 23, 2019).

MACY’S AND XPO LAST MILE SETTLE IC MISCLASSIFICATION CLASS ACTION BY DELIVERY DRIVERS AND HELPERS FOR $3.5 MILLION.  A California federal district court granted preliminary approval of a $3.5 million settlement reached in a proposed class action alleging independent contractor misclassification by a class of over 700  delivery drivers and helpers against Macy’s and XPO Last Mile.  XPO LM provides logistics services for Macy’s West Stores Inc., including arranging for delivery of certain consumer products and home furnishings that are sent out for delivery to consumers from the Macy’s Logistic & Operating Distribution Center in California. The named plaintiffs allege that they and the class members were not paid for all hours worked and were denied meal and rest breaks to which they were entitled. Macy’s and XPO LM denied these allegations and asserted that the drivers and helpers were not employed by either XPO LM or Macy’s. The $3.5 million settlement, which XPO LM agreed to pay on behalf of itself and Macy’s, provides for 60% of the settlement fund to be awarded to drivers and 40% to be allocated to helpers.  Garcia v. Macy’s West Stores Inc., No. 3:16-cv-04440 (N.D. Cal. Oct. 30, 2019).

XPO LOGISTICS RECEIVES FINAL APPROVAL OF $16.5 MILLION SETTLEMENT OF IC MISCLASSIFICATION CASE BROUGHT BY APPLIANCE INSTALLERS / DELIVERY DRIVERS.  A California federal district court has given final approval to a $16.5 million settlement reached between XPO Logistics and a class of drivers in an IC misclassification class action.  As we discussed in our prior blog post of July 8, 2019, the lawsuit alleged that XPO violated the federal Fair Labor Standards Act and California state wage and hour laws by misclassifying drivers as independent contractors and not employees. According to the drivers, XPO provides delivery services to retail merchants like Home Depot and Lowe’s; those companies contract with XPO to provide the delivery and basic installation services attendant to newly purchased appliances and removal of old appliances from their customers’ homes in California. The drivers claimed, among other things, that XPO reserved the rights to determine the locations where the drivers pick up and drop off merchandise assigned to them; controlled the order and timing of deliveries; required the drivers to wear XPO uniforms and follow customer service standards; determined the year and branding of the vehicles driven by the drivers; unilaterally determined the fees to be received by the drivers; and required the drivers to follow specific methods regarding how to move and install appliances and interact with customers. Estimated payments to drivers range from a high of over $140,000 to a low of $70, with an average of approximately $14,775 per driver. The settlement further provides $4,125,000 (25% of the gross settlement fund) for plaintiffs’ counsel’s fees and expenses, and $120,000 for class representative service awards. Carter v. XPO Logistics, Inc., No. 3:16-cv-01231 (N.D. Cal. Oct. 18, 2019).

DENTAL CONSULTANTS SETTLE CLASS ACTION INDEPENDENT CONTRACTOR MISCLASSIFICATION LAWSUIT FOR $3.4 MILLION.  Dental consultants including dentists and hygienists engaged to evaluate dental insurance claims have reached a proposed $3.4 million settlement of proposed class and collective action alleging wage and hour violations under the Fair Labor Standards Act, the Employee Retirement Income Security Act, and various state labor laws (IL, NJ, NY and RI) due to their alleged misclassification as independent contractors instead of employees.  According to the complaint filed in United States District Court for the Southern District of New York against Metropolitan Life Insurance Company, the dental consultants evaluated claims for benefits submitted by policyholders, participants, and beneficiaries in employee benefit plans to determine whether the services rendered were dentally necessary. The consultants alleged that, among other things, they should have been classified as employees and been entitled to overtime compensation because the company allegedly exercised direction and control over them by dictating their maximum hours of work; requiring them to work at MetLife’s offices and record their hours of work on forms issued by MetLife; requiring them to use computer hardware and software that MetLife provided to the consultants at no charge; imposed guidelines as to how to perform the work;  trained them and supervised their work through managers; created standards by which to assess the quality and quantity of their performance; and assessed their performance under those standards. Under the terms of the proposed settlement, the eligible class members (approximately 120 dental consultants) would receive no less than $1,000 each; $1,260,000 is earmarked for attorneys’ fees; and $168,000 would be set aside for service awards to particular plaintiffs. The parties’ proposed settlement agreement contains a non-admission provision on the part of the company and there is no requirement that the company change its business practices.  The parties await approval of the proposed settlement by the federal district court judge.  McNeely v. Metropolitan Life Ins. Co., No. 1:18-cv-00885 (S.D.N.Y. Oct. 7, 2019).

DOORDASH SUCCEEDS IN COMPELLING ARBITRATION OF IC MISCLASSIFICATION CLAIM.  A Massachusetts federal district court has granted a motion to compel arbitration of wage and hour claims asserted by delivery drivers against DoorDash alleging IC misclassification. The drivers claim that DoorDash, a food delivery service that provides services throughout the United States via an on-demand dispatch system, violated the Massachusetts Wage Act by failing to pay the drivers at least the minimum wage and overtime compensation as a result of its misclassification of the drivers as independent contractors and not employees. DoorDash customers may request food delivery through the mobile app or website. The order is then electronically submitted to both the restaurant and a driver wishes to deliver the order. If the driver agrees to make the delivery, he or she picks up the food and transports it to the customer. The named plaintiff driver claims the drivers are paid a delivery fee plus any customer tips, but after paying their own expenses, including for their vehicle, gas, smartphone, and data plan, their wages fall below the minimum wage.

DoorDash made a motion to dismiss the complaint and compel arbitration of the driver’s claims citing the mutual arbitration provision contained on DoorDash’s mobile app. In granting DoorDash’s motion to compel arbitration, the court rejected the driver’s argument that his arbitration agreement falls within the Federal Arbitration Act’s exclusion for “contracts of employment … of any other class of workers engaged in … interstate commerce.” The court, applying the multi-factor Lenz v. Yellow Transp. Inc. test, concluded that the driver was not a “transportation worker” exempted by section 1 of the FAA.  While the court found that certain factors favored transportation worker status, it concluded that, overall, the facts militated more strongly against interstate transportation status, including that the driver did not allege that he ever crossed state lines; did not allege that drivers are offered routes that involve transporting meals across state lines; did not allege any commercial connection between any interstate food distributor and the customers that received prepared meals via the driver’s delivery; and did not allege any connection between the out-of-state manufacturers of packaged goods and DoorDash. The court stated remarked: “[T]he outcome of this case may well be different if a driver alleged that he crossed state lines to deliver goods, as might occur where a delivery driver is stationed close to a state’s border. Similarly, the outcome of this inquiry might be different for an on-demand driver who delivers groceries for a store that buys goods in interstate commerce.”  Austin v. DoorDash Inc., No. 17-cv-12498 (D. Mass. Sept. 30, 2019).

BARBERS PROVIDING SERVICES AT A CHAIN OF BARBER SHOPS ARE HELD TO BE INDEPENDENT CONTRACTORS.  A three-judge panel of the U.S. Court of Appeals for the 11th Circuit has affirmed a district court’s decision upholding a jury verdict that barbers who provided services at Florida chain of “Razzle Dazzle” barbershops were independent contractors and not employees. The barbers alleged that they were misclassified as ICs instead of employees and, as a result, were allegedly denied overtime compensation under the FLSA. A great deal of conflicting testimony regarding employment status was presented to the jury at the trial. The barbers introduced confidentiality and non-compete agreements describing them as employees; a staff manual detailing a dress code, attendance policy, and job-related duties; and testimony that they did not set their own schedule, were not allowed to choose what hair products to use, and were required to wear specific uniforms. In contrast, the barbershop owner testified that the barbers set their own schedules, wore what they wanted, were free to choose their own hair products, could set their own prices, could provide services to others as long as it was outside the geographic limitation in the agreement, had the opportunity for profit, and provided their own equipment. In affirming the district court’s denial of the barbers’ post-trial motions, the appellate panel concluded that the jury was entitled to make credibility determinations where conflicting testimony was provided by the parties and there was “at least some evidence” to support the jury’s verdict.  Romero v. Razzle Dazzle Barbershop Inc., No. 18-12689 (11th Cir. Oct. 29, 2019).

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.

© Locke Lord LLP | Attorney Advertising

Written by:

Locke Lord LLP

Locke Lord LLP on:

Readers' Choice 2017
Reporters on Deadline

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

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

JD Supra Privacy Policy

Updated: May 25, 2018:

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

This Privacy Policy describes how JD Supra, LLC ("JD Supra" or "we," "us," or "our") collects, uses and shares personal data collected from visitors to our website (located at www.jdsupra.com) (our "Website") who view only publicly-available content as well as subscribers to our services (such as our email digests or author tools)(our "Services"). By using our Website and registering for one of our Services, you are agreeing to the terms of this Privacy Policy.

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

Collection of Information

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

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

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

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

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

How do we use this information?

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

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

How is your information shared?

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

How We Protect Your Information

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

Children's Information

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

Links to Other Websites

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

Information for EU and Swiss Residents

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

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

You can make a request to exercise any of these rights by emailing us at privacy@jdsupra.com or by writing to us at:

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

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

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

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

California Privacy Rights

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

You can make a request for this information by emailing us at privacy@jdsupra.com or by writing to us at:

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

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

Access/Correct/Update/Delete Personal Information

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

Changes in Our Privacy Policy

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

Contacting JD Supra

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

JD Supra Cookie Guide

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

How We Use Cookies and Other Tracking Technologies

We use cookies and other tracking technologies to:

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

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

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

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

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

  • HubSpot - For more information about HubSpot cookies, please visit legal.hubspot.com/privacy-policy.
  • New Relic - For more information on New Relic cookies, please visit www.newrelic.com/privacy.
  • Google Analytics - For more information on Google Analytics cookies, visit www.google.com/policies. To opt-out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout. This will allow you to download and install a Google Analytics cookie-free web browser.

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

Controlling and Deleting Cookies

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

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

Updates to This Policy

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

Contacting JD Supra

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

- hide

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