Summaries of Administrative Appeals Office EB-5 Decisions Posted for 2012

by Baker Donelson

Below are my summaries of the 2012 EB-5 AAO decisions recently posted by USCIS, which can be a accessed from > Administrative Decisions and choosing the "Folders" for B7 and K1. A few issues of potentially broad implications are shown in italic type, and two potentially urgent issues (validity of state TEA determinations and counting of indirect construction jobs) are underlined.

Regional Center Applications

Aug062012_01K1610.pdf: Regional center denial affirmed (filed prior to I-924 existence). The applicant in North Carolina suggested but according to the AAO did not prove that it was a non-profit state or county economic development entity operating on behalf of the government. The entity failed to show that any of $4.3 million available to the county for economic development was actually available to the regional center applicant for its operating purposes.  The applicant submitted some examples of projects already completed outside the proposed regional center area as "exemplars" of projects it would pursue, submitted a copy of the RIMS II methodology handbook, and requested an array of 10 or 12 two- or three-digit NAICS codes, but the AAO dismissed those as not relevant, not a good faith effort at providing “verifiable detail” about job creation, and as having been injected into the application after the date of filing [Note: USCIS normally is forgiving on this point in I-924 applications but brings out that argument as an alternative in case other real reasons for denial might not stick in court.]  The applicant seems to have been laying the foundation for a lawsuit challenging USCIS regulations, which require "verifiable detail" in regional center applications, in light of the subsequently enacted appropriations language requiring only “general predictions.” The AAO stood its ground on the regulations, and it will be interesting to see if the applicant has litigated.

Dec042012_01K1610.pdf: In a similar application in Indiana, an economic development entity requested 12 industries without specific business plans.  The AAO analyzed the most specific plan submitted, for a hotel project, and found it lacking in detail and subject to inconsistencies in projecting job creation.  It found more vagueness and job creation inconsistencies concerning two bridge construction projects.  In discussing the hotel project and a prediction that “construction of the hotel will yield 520 direct and indirect jobs,” the AAO makes a startling statement that “As the business plan does not include any timelines establishing that the construction jobs will last at least two years, the applicant cannot include those jobs.” This conclusion, as to the indirect construction jobs, is contrary to the USCIS memo of December 11, 2009, the USCIS Adjudicator’s Field Manual in which it is embodied, and many recent regional center and I-526 approvals, and would undermine quite a few pending projects in the market.  We can only hope that the AAO accidentally overlooked the separate treatment of indirect jobs in that broader discussion, perhaps because the applicant’s analysis did not distinguish between the two.

I-526 Petitions

Jan052012_01B7203.pdf: motion to reopen or reconsider was untimely.

Jan092012_01B7203.pdf: I-526 denial affirmed. Non-TEA, non-RC. The AAO held that: (1) a pattern of receiving large, inadequately explained gifts for investment purposes by the petitioner and a convoluted business history and path of funds for the investment; (2) a promise to refund the investment if the I-829 is denied is unacceptable [this corresponds to an oblique reference in the USCIS December 11, 2012 memo], and because such a promise must be premised on reserving the funds to honor such promise, it cannot be corrected after the date of filing; and (3) the choice to hold the funds in escrow might mean that the project gets finished without use of the EB-5 funds, eliminating the necessary nexus for approval [no mention of any bridge financing arrangements].

Jan102012_01B7203.pdf: motion to reopen or reconsider was untimely.

Apr092012_01B7203.pdf: I-526 denial affirmed. Non-TEA, non-RC. The investor made inconsistent claims that she (a) loaned the money to five different companies outside China that repaid her by paying the proceeds to the NCE and (b) provided the funds to a friend who arranged the loans to the five entities. The loans were made a year before the funds were provided to the friend, and there were discrepancies about the amounts that an attorney’s letter could not resolve. Interestingly, the general strategy of moving the funds from her company was not specifically criticized.  Only inconsistencies and gaps in documentation were the basis for denial.  The project also lacked timeline with milestones to support the projection of job creation.

Apr172012_01B7203.pdf, Apr172012_03B7203.pdf, Apr172012_07B7203.pdf, Apr172012_09B7203.pdf:  I-526 denial or revocations (some of both) affirmed. Pages 7 and 10-15 of one of the 17-page decisions are missing, but the other decisions appear to be essentially the same decisions with tiny variations, so the summaries are merged. The investors in one of many joint ventures, organized by a company called Caervision to put TV screens with content into medical offices, was found to have made misrepresentations [giving rise to permanent ground of inadmissibility] about the NCE’s lease of space. Some related entity was alleged to have leased 11,000 square feet of space in Johnstown, Pennsylvania to house the various joint ventures who would sub-lease their respective space. The AAO concluded that only 375 square feet of space had been leased and not even fully furnished, and upon site inspection no meaningful work had gone on, and I-9 documentation about allegedly existing but apparently shared workers had been "altered" to make it appear that certain employees were working for several project entities at the same time.  The parties to the joint venture seem to have been confused with a related corporation, and the tax filings allocate all losses to the joint venture partner, not the investor; thus the at-risk problem. The investor appears to have claimed regional center affiliation purely by means of location without reference to any agreement with the regional center, so USCIS would consider only direct job creation. USCIS rejected a TEA letter that at time of I-526 filing had been over 1.5 years old based on over 2-year old data. Large and small discrepancies in expenses and financial statements were highlighted.  Apparently on appeal the investor claimed that the business plan had changed to a call center for which only vague plans were laid out, which AAO found to be a material change and generally inadequate requiring denial/revocation. One case (Apr172012_06B7203.pdf) added source of funds problem summarized by AAO as follows: "The record does not trace the funds transferred by the petitioner's ‘close friends’ back to her Chinese Citibank debit account. Moreover, the notations for some of the transfers raise concerns about whether these funds were intended for the petitioner's investment."

Apr172012_04B7203.pdf: I-526 denial affirmed. Non-TEA, non-RC. The investor owned Pau Holdings, LLC, which owned 75% of Pearl Imaging, LLC, which was to operate medical diagnostic imaging facilities without regional center affiliation. The AAO confirmed that the holding company needed to own 100% of the job creating enterprise (without an RC), and the claimed purchase of the remaining 25% after filing was deemed material and too late.  The investor failed to show that she had committed the requisite funds to the enterprise, under a factually complex analysis.  The AAO held that signing a lease for space with personal funds to back it up does not constitute capital at risk, because the enterprise might generate ongoing income sufficient to make the lease payments. It appeared also that the investor may have purchased the assets of an ongoing business, so that the jobs involved might not be new.

Jul102012_01B7203.pdf: I-526 denial affirmed. Non-TEA, non-RC. The investor proved that $5,000 cash was her personal funds, but as to $1 million+ in inventory transferred from her business in Mexico, the AAO found that she needed to have personally purchased the inventory from her company or otherwise liquidated it before transfer [focusing on a point seemingly missed in one of the cases summarized above], that the self-valuation of equipment was not reliable, that the identities of the transferring and transferee parties were not sufficiently documented, that no transit broker was identified, and that the only premises decipherable for the NCE were her personal apartment not apparently big enough to house the inventory.

Jul162012_01B7203.pdf: I-526 denial affirmed. Non-TEA, non-RC. The investor established perhaps five new employees so far for an existing business purchased, and a 4-page business plan submitted on RFE response was devoid of competitive market assessment to justify projections of future hiring. The AAO refused to consider a new business plan submitted on appeal. The AAO questioned source of funds based on sale of stock that had without explanation increased in value from 3,000 RMB to 150 million RMB in 17 months.

Aug072012_01B7203.pdf: I-526 denial affirmed. Non-RC. Investor first claimed to have purchased the property on which the bank loan of capital was collateralized, but upon USCIS’ questioning of her income she claimed that her husband had been given the property as a bonus from an employer whose original support letter and tax filings had made no mention of the property. Also, the investor failed to document and explain how the property had quadrupled in value in two years since acquisition or how the bank had relied on an appraisal dated the day after the loan documents. Also there was a gap in records of bank transfers. In an additional finding that could have significant repercussions for other EB-5 investors, the AAO disregarded a May 18, 2010 TEA designation letter based on 2009 data in an I-526 petition filed on March 25, 2011, stating, "[t]he fact that an area was once an area of high unemployment does not mean that it still is." [Note: Washington state TEA letters do not generally indicate a period during which it is valid. It is unclear whether a state letter explicitly providing for one-year validity would be considered valid by USCIS even after available data has been updated.]

Aug202012_01B7203.pdf: I-526 denial affirmed. Non-TEA, non-RC. Investor put $100,000 into the NCE and showed $900,000 in her personal bank account, but did not transfer the $900,000 into the NCE (an existing auto repair and body shop) or into an escrow account or sign a promissory note secured by collateral. Instead, her purchase agreement for the stock required payment by a certain date “or such later date as may be mutually agreed to in writing by all Parties.” The AAO held that the funds were not committed at risk in the NCE under these circumstances. Also the agreement seems to have been susceptible to a reading that it was to replace other capital rather than for expansion of the existing business. The AAO also found several breaks in the path of funds involving the sale of a foreign tourism business and refused to consider new wire transfer evidence submitted on appeal.  Finally, the AAO found that the business did not qualify as a "troubled business" for counting preserved jobs. In doing so, the AAO might improperly have compared prior net worth figures to most current year net income figures.  Footnote 2 is worthy of general awareness on troubled business determinations:

"Where an S corporation's income is exclusively from a trade or business, USCIS considers net income to be the figure for ordinary income, shown on line 21 of page one of the petitioner's IRS Form 1120S. Where an S corporation has income, credits, deductions or other adjustments from sources other than a trade or business, they are reported on Schedule K. If the Schedule K has relevant entries for additional income, credits, deductions or other adjustments, net income is found on line 18 of Schedule K. See Instructions for Form 1120S, at http://www.irssov/pub/irs-pdf/ill20s.pdf [accessed on February 21, 2012] (indicating that Schedule K is a summary schedule of all shareholders' shares of the corporation's income, deductions, credits, etc.). Because the petitioner had additional deductions shown on its Schedule K for 2007, 2008, 2009, the petitioner's net income is found on Schedule K of its tax returns."

Aug232012_01B7203.pdf: I-526 denial affirmed. Non-TEA, non-RC. The investor provided funds derived from these assets to multiple private currency exchange dealers, who subsequently invested the funds in the NCE. The AAO questioned the source of these funds as being sufficient in light of living expenses during the period during which they were earned, and it found insufficient evidence of the connection between her capital and the dealers’ transfers (i.e., gaps). The AAO in principle refused to consider new evidence of transfers on appeal but nevertheless reviewed the new evidence and found it lacking. The AAO found the business plan, which initially was to warehouse and distribute pianos but on RFE response was expanded to include importation and sale of eyeglass frames and rental of warehouse space, fatally vague in light of Matter of Ho.

I-829 Petitions

No I-829 decisions were posted by AAO. This could be because (1) a smaller percentage of I-829 filings are denied, and (2) USCIS is not "certifying" denials to AAO and is accompanying denials with notices to appear in immigration court, thereby removing jurisdiction from AAO.


AO continues to require verifiable detail to support regional center indirect job creation projections, detailed business plans for all projects under Matter of Ho, and seamless source and path of funds evidence. AAO's holdings about the duration of TEA designations requires clarification with USCIS, with implications for larger projects that need to subscribe investors across the points at which new data becomes available (usually late Spring). AAO's ruling about construction jobs probably was meant to be focused on direct jobs without awareness of USCIS' different treatment for indirect construction jobs, but USCIS clarification would be helpful to the market.


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.

© Baker Donelson | Attorney Advertising

Written by:

Baker Donelson

Baker Donelson 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.