Potential Immigration Consequences For Workers And Investors In The Canadian Cannabis Industry

by Littler
Contact

[co-author: Sam Lazzaro*]

Canada legalized the recreational use of marijuana effective October 17, 2018. Although many American states have loosened their marijuana restrictions, including those on the U.S.-Canada border like Washington, Michigan, and Maine, the use and possession of marijuana and marijuana products remain illegal under U.S. federal law. Mike Niezgoda, a spokesman at the U.S. Customs and Border Protection (CBP) office in Buffalo, has indicated that those participating in the marijuana business may be turned away at the border, saying: “Working or having involvement in the legal marijuana industry in U.S. states where it is deemed legal or Canada may affect an individual’s admissibility to the U.S.”1 Likewise, according to Todd Owen, Executive Assistant Commissioner for CBP, “[f]acilitating the proliferation of the legal marijuana industry in U.S. states where it is deemed legal or Canada may affect an individual’s admissibility to the U.S.”2 While Mr. Owen did not specify any minimum level of investment in the industry, he signaled the agency’s focus was on those attempting to bring the sector to the United States.3 Border agency press officer Stephanie Malin clarified “that industry workers or investors could face a permanent ban on travelling to America.”4 As she reiterated, “[u]nder U.S. federal law, marijuana isn’t legal.”5

Crossing the Border with Cannabis

The Canadian Cannabis Act creates a strict legal framework for controlling the production, distribution, sale, and possession of cannabis across Canada. Despite the fact that cannabis will become legal and regulated in Canada, it is illegal now, and will remain illegal, to transport cannabis across Canada’s international borders. This prohibition applies even if an individual is authorized to use cannabis for medical purposes, and even if an individual is traveling to or from an area where cannabis has been legalized or decriminalized.6 In short, the Cannabis Act does not change the border rules of either the United States or Canada.

In the U.S., the use and possession of cannabis is illegal under federal law for any purpose as classified under the Controlled Substances Act of 1970 (CSA). At the state level, however, policies regarding the medical and recreational use of cannabis vary greatly, and in many states conflict significantly with federal law. As of November 2018, the medical use of cannabis (in some form) is legal in 31 states and the District of Columbia.7 Ten states and the District of Columbia have adopted rules permitting the use of marijuana by adults for recreational purposes.8 However, for immigration purposes, it is the federal law that controls. It is a federal offense to possess, give away, sell, cultivate, import or export cannabis. This prohibition includes any activity, commercial or otherwise, involving any part or derivative of the plant.9 Criminal convictions almost always carry immigration consequences, but in the case of cannabis and other controlled substances, a mere admission of engaging in prohibited conduct—and sometimes even evidence of the conduct without any admission—can have immigration consequences.

Immigration Consequences: A Potential Lifetime Ban

The U.S. Immigration and Nationality Act (INA) makes inadmissible anyone with a conviction for a violation of, or a conspiracy or attempt to violate, any law or regulation of a state or country related to a controlled substance such as cannabis.10 Even when there is no conviction, an admission to acts that constitute the essential elements of any law or regulation of a state or country related to a controlled substance is sufficient for a finding of inadmissibility.11 Further, a noncitizen is inadmissible if a CBP officer merely has “reason to believe” that the person is or has been a trafficker of any controlled substance,12 or has participated—aided, abetted, assisted, conspired, or colluded—in the trafficking of any controlled substance, notwithstanding a conviction.13

Inadmissibility attaches for life and cannot be waived by section 212(h)14 of the INA.

Determinations regarding admissibility are made on a case-by-case basis by CBP officers based on the facts and circumstances known to the officer at the time. Noncitizens who reveal they are employed by the newly legal cannabis industry abroad in any capacity may be deemed to be a knowing aider, abettor, assistor, conspirator, or colluder in controlled substance trafficking, and denied entry into the United States. Additionally, the border search exception, which allows search and seizure without probable cause, applies at the border and its functional equivalents.15 Officers may search a person’s wallet, or review the contents of a laptop or cell phone, for example. If the officer notices something cannabis-related in that search, it may lead to an inquiry regarding the connection between cannabis and the noncitizen. Providing a government officer with a “reason to believe” that a noncitizen is associated with drug trafficking, which could include normal association with state- or country-legal cannabis, is sufficient to make the noncitizen inadmissible.

Understanding the parameters of what “associating with drug trafficking” may mean requires a look at how the U.S. government views working within the cannabis industry. In January 2018, the former head of U.S. Department of Justice (USDOJ), Attorney General Jefferson Sessions, released new guidance (“the Sessions Memo”) that formally rescinded prior guidance known as the Cole Memo.16 The Cole Memo17 was written by former U.S. Attorney General James M. Cole in 2013, and indicated that prosecutors and law enforcement should focus only on the following priorities related to state-legal cannabis operations:

  • Preventing the distribution of marijuana to minors;
  • Preventing revenue from the sale of marijuana from going to criminal enterprises, gangs and cartels;
  • Preventing the diversion of marijuana from states where it is legal under state law in some form to other states;
  • Preventing state-authorized marijuana activity from being used as a cover or pretext for the trafficking of other illegal drugs or other illegal activity;
  • Preventing violence and the use of firearms in the cultivation and distribution of marijuana;
  • Preventing drugged driving and the exacerbation of other adverse public health consequences associated with marijuana use;
  • Preventing the growing of marijuana on public lands and the attendant public safety and environmental dangers posed by marijuana production on public lands; and
  • Preventing marijuana possession or use on federal property.

The Sessions Memo of January 2018 took a much more hardline approach, essentially overturning the Cole Memo, emphasizing that the CSA remains the law of the land and that the cultivation, distribution, and possession of marijuana continues to be illegal under federal law.   Consistent with that position, and as noted earlier, CBP has warned that “[g]enerally, any arriving alien who is determined to be a drug abuser or addict, or who is convicted of, admits having committed, or admits committing, acts which constitute the essential elements of a violation of (or an attempt or conspiracy to violate) any law or regulation of a State, the United States, or a foreign country relating to a controlled substance, is inadmissible to the United States.”18

Still, the USDOJ currently does not set any bright-line rules for the enforcement of the CSA as to marijuana-related activities. Thus, the principles of federal prosecutorial discretion, judicial resources, and the case-by-case interpretation and application of these standards are critical to predicting the factors that will shape whether federal prosecutors will seek to enforce the CSA with respect to marijuana. Likewise, the case-by-case interpretation and application of the “reason to believe” standard will shape how border officials approach and will seek to enforce the inadmissibility of individuals who are suspected of marijuana use, trafficking, etc.

Practical Concerns

There are significant business opportunities, as well as legal risks, presented by the evolving, quasi-legal cannabis industry. Cannabis-related activities remain technically illegal under federal law. The USDOJ does not require the enforcement of the CSA as to cannabis, particularly in states where the substance is legal, or when businesses only indirectly support the cannabis industry by providing legitimate services and investments. But that position may be largely attributable to U.S. House of Representative imposed caps on spending in support of these efforts. Any prior failure to act does not mean that that the USDOJ will not seek to enforce federal law on its borders going forward.

Our understanding is that CBP officials are not planning to go out of their way to interrogate every individual crossing the border about marijuana use. However, other factors may cause them to raise the topic. Todd Owen, in his interview with Politico noted, “Our officers are not going to be asking everyone whether they have used marijuana, but if other questions lead there — or if there is a smell coming from the car, they might ask.” Likewise, marijuana residue could be detected by CBP inspection dogs and lead to further questioning. According to Mr. Owen, if asked about past drug use, travelers should not lie. “If you lie about it, that’s fraud and misrepresentation, which carries a lifetime ban.”19

For those individuals that work in the cannabis industry, questions from border agents are difficult to navigate. Often, border agents will ask the individual’s occupation, and while mere tourists to the U.S. may not be barred from entering on the basis of their profession, those who have plans to engage with U.S. companies in the marijuana industry may be seen as engaged in criminal activity.20 As the Sessions Memo iterates, marijuana-related activities can serve as a basis for the prosecution of other crimes, such as money laundering and the unlicensed transmission of money under 18 U.S.C. § 195621 and § 1960,22 respectively.

This field of law is constantly and rapidly changing. These open questions will undoubtedly result in litigation that will more definitively shape the boundaries of permissible engagement with companies in the marijuana industry. In the meantime, border officials have broad discretion to enforce inadmissibility laws, and employers and foreign nationals alike should be cognizant of the risks involved.

As a practical matter, employers and individuals should be aware of the following:

  1. As indicated earlier, lying about or misrepresenting involvement in the cannabis industry—or personal use of marijuana—could result in a lifetime ban from entering the United States.
  1. It remains illegal to bring or transport marijuana, or marijuana products, across U.S. borders, including the border with Canada.
  1. If you or a family member has involvement in the legal marijuana industry, be aware of the limitations as stated above.
  1. Note that there is no clear guidance or bright-line test for determining an individual’s exposure to enforcement in this area.
  1. Finally, enforcement in this area is evolving, and is subject to shift rapidly as CBP determines how to approach the change in law in Canada.

* Sam Lazzaro is an immigration law clerk in Littler’s Miami office.

Gregg Quinn, Canada’s Legal Weed Creates Risk for Investors at U.S. Border, Bloomberg, Sept. 14, 2018.

Luiza CH. Savage, U.S. official: Canadian marijuana users, workers and investors risk lifetime border ban, Politico, Sept. 13, 2018.

Id. 

Gregg Quinn, Canada’s Legal Weed Creates Risk for Investors at U.S. Border, Bloomberg, Sept. 14, 2018.

Id. 

Government of Canada, Cannabis and International Travel (modified on Oct. 17, 2018).

National Conference of State Legislatures, State Medical Marijuana Laws (Nov. 8, 2018).

Michigan voted to become the 10th state to permit the recreational use of cannabis products on November 6, 2018; the law is expected to become effective in December 2018.

See 21 U.S.C. § 841.

10 See INA § 212(a)(2)(A).

11 See INA §§ 101(a)(43)(B), 212(a)(2)(A)(i)(II).

12 See Matter of Casillas-Topete, 25 I. & N. Dec. 317 (BIA 2010). 

13 INA § 212(a)(2)(C)(i).

14 Section 212(h) of the INA provides that the Attorney General may, in his or her discretion, waive the inadmissibility of certain aliens, including those guilty of “a single offense of simple possession of 30 grams or less of marijuana” under specified circumstances.

15 United States v. Flores-Montano, 541 U.S. 149 (2004).

16 Jefferson B. Sessions, III, U.S. Att’y Gen., Memorandum for All United States Attorneys: Marijuana Enforcement (Jan. 4, 2018).

17 James M. Cole, Deputy Att’y Gen., Memorandum for All United States Attorneys: Guidance Regarding Marijuana Enforcement (Aug. 29, 2013).

18 U.S. Customs and Border Protection, CBP Statement on Canada’s Legalization of Marijuana and Crossing the Border (updated Oct. 9, 2018).

19 Luiza CH. Savage, U.S. official: Canadian marijuana users, workers and investors risk lifetime border ban, Politico, Sept. 13, 2018.

20 U.S. Customs and Border Protection, CBP Statement on Canada’s Legalization of Marijuana and Crossing the Border (updated Oct. 9, 2018).

21 See 18 U.S.C. § 1956 (Laundering of Monetary Instruments).

22 See 18 U.S.C. § 1960 (Prohibition of Unlicensed Money Transmitting Businesses).

[View source.]

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.

© Littler | Attorney Advertising

Written by:

Littler
Contact
more
less

Littler 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.