SEC Disclosure in the Time of COVID-19

McGuireWoods LLP

The industry has seen a number of Securities and Exchange Commission disclosure-related developments affecting public companies during the outbreak of the novel coronavirus (COVID-19), including:

  • SEC guidance on conducting annual meetings
  • Proxy advisory firm adjustments for virtual annual meetings
  • Disclosure obligations to consider in the COVID-19 pandemic
  • SEC’s exemptive order relating to coronavirus
  • Insider trading policy considerations
  • Board oversight of the company’s COVID-19 response

Read on for an overview of each, including analysis and implications for public companies.

SEC Staff Guidance on Conducting Annual Meetings

On March 13, 2020, the SEC staff (not just the staff of the Division of Corporation Finance) issued guidance for conducting annual shareholder meetings in the time of the coronavirus pandemic that address (1) disclosing changes in the date, time or location of the annual meeting; (2) conducting virtual meetings; and (3) presenting shareholder proposals.

Noting that issuers are contemplating possible changes in their annual meetings due to the difficulties arising from COVID-19, the SEC staff advised that, from a federal securities law perspective, any issuer that has already mailed and filed its definitive proxy materials may notify shareholders of a change in the date, time and location of its annual meeting without mailing additional soliciting materials or amending its proxy if it:

  1. issues a press release announcing the change in date, time or location of the meeting;
  2. files the announcement as “additional soliciting materials” on EDGAR; and
  3. takes all reasonable steps necessary to inform other intermediaries in the proxy process (such as any proxy service provider) and other relevant market participants (such as the appropriate national securities exchanges) of such change.

The SEC staff also advised registrants considering a virtual-only or “hybrid” (i.e., simultaneously in-person and virtual) annual meeting to provide notice of such meeting format to shareholders in a timely manner with clear directions of how to participate in such meeting. Issuers that have already filed and mailed their definitive proxy materials are allowed to follow the three steps noted above to announce these details to shareholders and other participants, rather than mailing this information to shareholders.

The guidance also encouraged issuers, to the extent feasible under state law, to provide shareholder proponents or their representatives with the ability to present their proposals at the annual meeting through alternative means, such as by phone, during the 2020 proxy season. Note that this SEC guidance relates to federal securities law compliance matters only, and is subject to applicable state law considerations and consultation with local counsel.

Proxy Advisory Firm Responses to COVID-19

The proxy advisory firms Institutional Shareholder Services (ISS) and Glass Lewis have each updated their proxy voting guidelines in light of the COVID-19 outbreak. Many shareholder advisory groups and institutional investors have policies that disfavor virtual meetings. However, each of ISS and Glass Lewis has issued guidance that it expects shareholders to be more accommodating of hybrid and virtual annual meetings this year in light of the pandemic, but also expects companies to provide comprehensive disclosures in their proxy materials affirming the rights of shareholders to participate in meetings. Other corporate governance groups have cautioned that any exemptions be limited to the current crisis and not set precedent for future years.

Ongoing Disclosure Obligations

As the financial and operational impacts of the COVID-19 pandemic continue, public companies must consider how their disclosures should change to inform investors about these impacts. SEC Chairman Jay Clayton noted in January 2020 remarks that the impact of COVID-19 is an “uncertain issue where actual effects will depend on many factors beyond the control and knowledge of issuers. However, how issuers plan for that uncertainty and how they choose to respond to events as they unfold can nevertheless be material to an investment decision.” Some of the disclosures that may require updating, particularly for companies that are accessing the public markets, include the following:

1. Earnings or Revenue Guidance

Generally, there is no obligation to update guidance for interim results or events. However, companies that have issued guidance on their expected financial results should consider whether to modify, suspend or withdraw guidance due to the expected financial impact of the pandemic, particularly if the company has closed stores or factories, experienced supply chain interruptions or had to take other actions having a material impact on projected financial results. Companies may also consider whether it would be appropriate to wait to adjust guidance until they have more information to impart to investors or until the company is at the point in the reporting cycle when it would typically comment on existing guidance.

2. 8-K Filings

Companies are required to file current reports on Form 8-Ks only if an event occurs that falls within one of the enumerated triggering events called for by Form 8-K. Companies are advised to consult with counsel on whether a specific event related to the COVID-19 outbreak would trigger an 8-K obligation. To the extent a plant or business center is shut down, and the shutdown is material to the company as a whole after considering applicable business continuity measures, registrants should consider whether to file a “voluntary” Form 8-K (via Item 8.01).

3. Management’s Discussion and Analysis of Financial Condition and Results of Operations (MD&A)

In their Form 10-Ks, registrants are required to discuss any “known trends or uncertainties” that will impact, favorably or unfavorably, the liquidity, capital resources or results of operations of the registrant. In their Form 10-Qs, each quarter, registrants are required to disclose any material changes in these events. In light of the COVID-19 crisis, companies should consider how to best describe to investors the impacts on liquidity, capital resources and results of operations a prolonged health crisis might have. Such considerations could include reduced access to credit or material changes in the cost of accessing the capital markets (or an inability to access the capital markets). To the extent that a registrant has publicly disclosed in a 10-K its thoughts on trends impacting liquidity, capital resources or results of operations, if those disclosures need to be updated in light of the COVID-19 pandemic, the registrant should be sure to make corresponding changes in subsequent 10-Qs.

4. Proxy Statements

Any company that has not yet filed its annual meeting proxy statement may want to review it, particularly disclosures about the time, date and location of the meeting (i.e., virtual meeting considerations), 2020 expectations that might be included in a CEO letter to shareholders, and future outlook described in the Compensation Discussion & Analysis, to determine whether those disclosures might need updating for the pandemic and its potential impact on the company’s business and stakeholders.

5. Risk Factors

Registrants are required to include comprehensive risk factors in their annual reports on Form 10-K and disclose material changes to these risk factors on their quarterly reports on Form 10-Q. The SEC staff has repeatedly emphasized that a registrant’s risk factors should be specifically tailored to the circumstances of the company and the risk factors should discuss why an investment in the company’s securities could be risky. Accordingly, registrants should consider, among others, the following risks posed by the COVID-19 pandemic to a registrant’s business:

  • Supply chain disruptions
  • Loss of contracts or customers
  • Closure of stores/facilities
  • Travel disruptions
  • Government responses
  • International business risks
  • Significant operations in countries severely impacted by the pandemic
  • Loss of human capital or personnel
  • Interruption of production

In addition, registrants that already have a force majeure or similar risk factor that mentions public health crises should consider making sure that the risk factor is narrowly tailored to the specific risks of the company. In addition, companies should consider whether to include a specific COVID-19-related risk factor. Where the registrant is actually experiencing the events in a risk factor, it would not be appropriate for the risk factor to use wording that implies that the risk factor event has not happened yet.

6. Forward-Looking Statements

When issuing forward-looking information, to comply with the safe harbor in the Private Securities Litigation Reform Act of 1995, registrants must include meaningful cautionary statements identifying items that could cause their results to be materially different from those presented. Consequently, registrants should consider updating their forward-looking information to highlight potential impacts caused by the COVID-19 pandemic. This applies to not only Form 10-Ks, 10-Qs and 8-Ks, but also press release disclaimers.

7. Subsequent Events Disclosures

A potentially overlooked area for legal disclosure for public companies is the footnotes to financial statements, where disclosure may need to be included if the COVID-19 pandemic constitutes a “subsequent event” under Accounting Standard Codification (ASC) 855-10-20. Under ASC 855-10-20, a subsequent event is one that occurs after a balance sheet date but before the date financial statements are issued. This potential disclosure was also highlighted in a recent joint public statement by the SEC and PCAOB chairs, the director of the SEC’s Division of Corporation Finance and the SEC chief accountant, where the group discussed the potential exposure of companies to the effects of the COVID-19 pandemic and how such exposure could impact financial disclosures and audit quality.

8. Impairments

Companies may need to consider whether the impact of the pandemic may have impaired any assets (including goodwill) or was a triggering event for an impairment test. The financial performance of certain lines of business or other assets, including estimates of future cash flows and earnings, may be significantly affected by the direct or indirect impacts of COVID-19 events. These accounting determinations may require Form 8-K disclosure. Indicators of impairment include (but are not limited to) significant changes with an adverse effect on the entity that have taken place during the period, or will take place in the near future, in the (1) market or economic environment in which the entity operates; and (2) extent to which, or the manner in which, an asset is used or is expected to be used (for example, an asset becoming idle, plans to discontinue or restructure the operation to which an asset belongs, or plans to dispose of an asset before the previously expected date).

9. Internal Controls Over Financial Reporting

Registrants should consider how the coronavirus health crisis could impact their internal controls over financial reporting, including with respect to how such impact would need to be disclosed in public reports. Issues to be considered may include potential delays in completing testing, audits or financial statements due to personnel shortages or travel restrictions, and testing and analysis for “going concern.”

SEC Exemptive Order Relating to Coronavirus

Noting that disruptions to transportation and limited access to facilities, support staff and professional advisers as a result of COVID-19 could hamper the efforts of public companies to meet their filing deadlines, on March 4, 2020, the SEC staff announced conditional regulatory relief for certain public filing obligations. During the period from March 1, 2020, to April 30, 2020, registrants are exempt from certain filing requirements if the following conditions are met: the registrant (1) is unable to meet a filing deadline due to circumstances related to COVID-19, and (2) furnishes a Form 8-K (or, if eligible, a Form 6-K) by the later of March 16 or the original filing deadline of the report being delayed. This Form 8-K or 6-K must state all of the following:

  1. That the registrant is relying on the SEC’s exemptive order.
  2. A brief description of why the registrant cannot file the report on time.
  3. The estimated date by which the delayed report is expected to be filed.
  4. If appropriate, a risk factor explaining, if material, the impact of COVID-19 on the registrant’s business.
  5. If the reason the report cannot be filed timely relates to the inability of any person other than the registrant (such as a law firm or accounting firm) to furnish any required opinion, report or certification, the 8-K or 6-K must include as an exhibit a statement signed by such person stating the reasons why such person is unable to furnish the required opinion, report or certification on time.

Examples of reports that are potentially subject to this exemptive order include Forms 10-K, 10-Q and 8-K, and amendments thereof, as well as definitive proxy statements and related soliciting materials and amendments thereto, and Schedule 13Gs and amendments. Filings not covered by the exemptive order are Section 16 beneficial ownership reports on Forms 3, 4 and 5, and Schedule 13D filings or amendments to a previously filed Schedule 13D. For details, read the full text of the SEC’s exemptive order.

Insider Trading Concerns

Companies should also consider how potential effects from the COVID-19 outbreak on their business could constitute material nonpublic information. Insiders will likely have greater insight on how COVID-19 will affect a company’s business and financial results. It may be appropriate to close the trading window under the insider trading policy until the company has informed the public of material information related to the impact of the COVID-19 health crisis.

Board Oversight Concerns

During these uncertain times, it is particularly important for a public company board to exercise appropriate oversight of the company and its responses and plans to address the effects of the pandemic. Each company should ensure that management is regularly reporting to the board about the impact of COVID-19 on the company’s employees, customers, supply chain, financing and capital market activities, and liquidity, access to credit and other key resources. In addition, a company’s board and management should be in regular consultation about the effect of the pandemic on the company’s financial results and the company’s ongoing plans to address future effects of COVID-19. This may include discussing communication plans and crisis protocols in light of “social distancing” or “shelter in place” requirements or recommendations from government authorities or potential illness or quarantine affecting senior management or directors. Finally, companies should prepare to conduct future board or committee meetings remotely, especially if their directors are in “at-risk” cohorts.


The COVID-19 outbreak and its impact on the economy and public companies continue to evolve at unprecedented speed. As companies struggle with macro-economic shocks and work to keep their employees, customers and other stakeholders healthy, they should not neglect their ongoing disclosure requirements to the investing public. They should also bear in mind recent guidance from the SEC and proxy advisory firms, should consider potential insider trading concerns with insider-held securities, and should ensure that their boards of directors are kept abreast of all material developments to the company.

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.

© McGuireWoods LLP | Attorney Advertising

Written by:

McGuireWoods LLP

McGuireWoods 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 (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.