The Recent PTO Guidance on Subject Matter Eligibility: Lessons

by McDonnell Boehnen Hulbert & Berghoff LLP

A few years ago, former PTO Solicitor General Nancy Linck arose from the audience at the BIO International Conference to provide her thoughts on how the Office had responded to the Supreme Court's decisions in Mayo v. Prometheus Labs and Association of Molecular Pathologists v. Myriad Genetics (see "USPTO Provides Update on Myriad-Mayo Guidance").  General Linck voiced her disappointment at the manner in which the Office had attempted to craft rules consistent with those decisions; in her view, the Office's responsibility was to provide the Court (and the patent community) with the benefit of their expertise and craft rules consistent with the Constitutional mandate that the patent system promote progress (even if the Supreme Court left open the possibility that this would not be the case).  General Linck spoke forcefully and clearly from her heart, and she received (and deserved) a standing ovation that day.

On the podium and uncomfortably the recipient of General Linck's point of view was Drew Hirschfeld, at the time the head of the Office's legal department.  Today he is Commissioner for Patents, and in the years since that day the Office's pronouncements on how the law of patent-eligible subject matter should be applied have been both more favorable to patent applicants and more consistent with patents promoting innovation than were those first set of guidances.  Like Plato emerging from his famous cave, the Office opened the doors and drew back the shades of whatever closed room its officials inhabited in the first dark days of these Supreme Court precedents, and has since begun to craft guidances that permit (albeit still in only an attenuated fashion) applicants to receive patents more commensurate with their contributions to the Useful Arts.

The latest guidance, distributed to the Examination Corps on May 4th and to the rest of us on May 5th is an example of this changed mindset (see memorandum entitled "Formulating a Subject Matter Eligibility Rejection and Evaluating the Applicant's Response to a Subject Matter Eligibility Rejection").  This new guidance has been discussed here (see "USPTO Issues Update to Subject Matter Eligibility Guidance") and elsewhere.  While others properly ponder the minutiae and nuances of this guidance, it may be worthwhile to try to draw some more generalized lessons from them.  The first bit of good news is that the guidance is focused on the claims (where of course it should be).  Fortunately the Office seems content to abandon any attempt to accommodate outmoded concepts of "inventiveness" or "inventive concept" that are divorced from the statute, or to search for the "gist" or "heart" of the invention.  Rather, Examiners are instructed that they must identify the abstract idea, the law of nature/natural phenomenon, or product of nature in first prong of Mayo/Alice test in the claim language itself.  Moreover, the Memorandum draws a distinction between claim limitations that "set forth" a judicial exception (which are thus self-evident) and those that merely describe an exception (where the Examiner must "explain subject matter those limitations describe, and why the described subject matter is a judicial exception").  This portion of the memorandum also requires the Examiner set out a reasoned rationale for the arguments regarding the presence of an abstract idea, the law of nature/natural phenomenon, or product of nature in the claim and whether such claim elements recite or are directed to a judicial exception.

Turning to the second prong, whether the claim recites "significantly more" than the abstract idea, the law of nature/natural phenomenon, or product of nature, Examiners must identify the additional elements of the claim (again, expressly and clearly) and explain why these elements taken individually and in combination do not amount to a claim as a whole that is significantly more than the judicial exception.  This portion of the Memorandum emphasizes both considering the additional elements in combination and considering the claim as a whole.  (However, and perhaps inevitably, the analyses set forth in the Examples 28-31, "atomize" these elements and their relationship to the abstract idea, the law of nature/natural phenomenon, or product of nature, before joining them, sometimes in several combinations, to probe whether the combination supports a conclusion of eligibility where the individual elements themselves do not.)  In performing this assessment, the Memorandum instructs Examiners to identify either instances where courts have recognized elements or combination of elements to be "well-understood, routine or conventional," or the skilled worker would so recognize the elements, again considered individually or in combination.  The Memorandum in this regard contains one important "caution," wherein:

[M]ere knowledge of the particular laboratory technique or use of the particular laboratory technique by a few scientists is not sufficient to make the use of the particular laboratory technique routine or conventional in the relevant field.

The Memorandum has, it seems, also been influenced by the Office's current patent quality initiative, emphasizing that rejections grounded in Section 101 must set out the rejections' rationale with "clarity."

The Examples (which will be separately discussed in this space), contain their own caution:  that they are intended to be illustrative only, and that Examiners (and presumably applicants and the public) should not rely upon them in asserting (or rebutting) rejections under Section 101.  (This admonition seems a bit unrealistic, particularly from the applicants' side, because it will certainly prove hard to cite these examples should a claim be "on all fours" with one of them.  Although alternatively this may be nothing more than a caveat that just because a claim resembles an example applicants should not be surprised if the Office decides that a particular claim is nevertheless patent ineligible.)

Taking the examples as a whole and considering both the express claim language and the Office's analysis of eligibility vel non of each of them, some trends and (current) PTO conclusions regarding eligibility are clear.  For products that can be considered "products of nature," those comprising alterations in the compounds not found in nature (e.g., mutations, chemical reactions, changes in structure or physical form) are eligible.  This is not a change in Office policies; earlier examples have made this eligibility determination.  In these Examples changes other than structural ones are also considered patent eligible by the Office; these include formulations (particularly with components not found together in nature) that change properties or functional characteristics of product of nature, as well as changes in physical form (such as crystal structure) provided that these changes are related to changes in functional properties (in Example 30, for example, naturally occurring crystals of a natural sweetener are rendered eligible by converting them to more homogeneous in size and having better dissolution properties.  The Office also exemplifies unconventionality of other aspects of the claimed invention (such as using microneedles for vaccination with otherwise patent-ineligible peptides; Example 28) to support eligibility.

For method claims, and particularly methods related to arriving at a diagnosis of disease (Example 29), illustrate an anomaly (albeit at the same time providing some comfort for claiming such methods going forward): detection methods per se (that do not recite a correlation that can be characterized as a law of nature) are eligible, if only because by not reciting anything that could be considered a law of nature the analysis is not implicated.  Even for methods that do recite a correlation that could be considered a law of nature the Office interprets those that also recite novel reagents (porcine antibodies or monoclonal antibodies) or methods (hybridization detection methods such as SNOM or new amplification methods, such as "Cool Melt" PCR (all of which are hypothetical)) to be eligible.  Method of treatment claims (which have not been held by courts to be patent ineligible (but see Bristol-Myers Squibb v. Merck) are considered eligible by the Office in these Examples when they comprise novel treatment methods of administration to patients diagnosed using the method, or specific treatment methods of administration to patients diagnosed using the method.  Indeed, one lesson gleaned from the Examples is that claims reciting elements at a high level of generality are more likely to be considered ineligible (despite the Federal Circuit's treatment of Myriad's claims in Myriad Genetics v. Ambry).

Turning to what is not patent eligible according to these Examples, products of nature per se remain (as they always have been) ineligible (the Office making ineligibility more explicit that even when claimed at certain percentages or in combination with other naturally occurring excipients such as water that do not change any of the product's properties).  For diagnostic methods, Mayo and AMP v. Myriad (Federal Circuit) compels the conclusion that such claims broadly reciting the correlation between a marker and a disease are ineligible (indeed, Example 31 provides modifications of the BRCA gene claims in eligible and ineligible embodiments).  The Office's rationale is also based on the use of "mental steps" in making the correlation, a conclusion that is not mandated by the case law.  Nevertheless Example 29 sets forth this rationale in its analysis of claim 2:

Next, the claim as a whole is analyzed to determine whether any element, or combination of elements, is sufficient to ensure that the claim amounts to significantly more than the exception.  Besides the law of nature, the claim recites additional steps of obtaining a plasma sample from a human patient (step a), and detecting whether JUL-1 is present in the plasma sample by contacting the plasma sample with an anti-JUL-1 antibody and detecting resultant binding between JUL-1 and the antibody (step b).  Obtaining a sample in order to perform tests is well-understood, routine and conventional activity for those in the field of diagnostics.  Further, the step is recited at a high level of generality such that it amounts to insignificant presolution activity, e.g., a mere data gathering step necessary to use the correlation.  Detecting whether JUL-1 is present in the plasma sample merely instructs a scientist to use any detection technique with any generic anti-JUL-1 antibody.  When recited at this high level of generality, there is no meaningful limitation, such as a particular or unconventional machine or a transformation of a particular article, in this step that distinguishes it from well-understood, routine, and conventional data gathering activity engaged in by scientists prior to applicant's invention, and at the time the application was filed, e.g., the routine and conventional techniques of detecting a protein using an antibody to that protein.  Further, it is well established that the mere physical or tangible nature of additional elements such as the obtaining and detecting steps does not automatically confer eligibility on a claim directed to an abstract idea (see, e.g., Alice Corp. v. CLS Bank Int'l, 134 S.Ct. 2347, 2358-59 (2014)).

This assessment also extends the ineligibility concept for these claims to more expressly base it on the "information" content (consistent with Judge Dyk's analysis in Genetic Technologies v. Merial).

While on balance this Guidance and the Examples illustrating the Guidance are an improvement on earlier iterations, the analysis continues to be frustrated by resistance to fully embracing consideration of the claims as a whole.  It is unclear why this analysis should not arrive at patent eligibility for using a conventional method with a novel biomarker to produce a novel result (even if it is based on an underlying law of nature).  Mayo is not to the contrary:  recall that every step in the recited method had been performed in the prior art, so that the only inventive aspect was in the correlation.  By definition, using a conventional method with a novel biomarker to produce a novel result is not the same, and certainly "promotes progress" pursuant to the Constitutional mandate.  Also absent (but here representing a sin of omission) is an express recognition that differences in purity with functional effects (the difference between chewing a pound of yew bark and taking a pill, for example), or producing a product having a specific activity different from what is found in nature, should be patent eligible.  Even in the vaccine example (#28) the Office did not include instances of, inter alia, immunological assays like sandwich assays to distinguish what occurs in nature and what is invented by man.  The Office also seems to have conflated (or, more kindly, synthesized) the "routine, well-understood and conventional" standard from Mayo into the Myriad product of nature analysis; while it may be likely that the Supreme Court will one day perform that synthesis, prudence suggests that we let the Court do it any not have the Office try to help.

It should also be recognized that the Office expressly did not consider in drafting the Guidance or the Examples recent case law (including Sequenom and Merial) and that at least one of the claims (Claim 1 of Example 28) that the Office considers patent eligible would not be considered patent eligible under the Federal Circuit's Sequenom decision.  In view of the fact that Sequenom filed a petition for certiorari that the Supreme Court has not granted or denied the eligibility of such claims must be at best considered provisional.

At a high level of generality, it can be understood that what the Office is unwilling to acknowledge (and perhaps doesn't think it can, another instance of hands being tied by inelegant expressions of the law by the Supreme Court case law) is the distinctions attendant on qualitative and quantitative differences between what is in nature (and thus perhaps should be "avallable to all men"):  when differences in use (taxol) or novel properties related to concentration, specific activity, etc. evince "the hand of man" then eligibility should be acknowledged.  This Guidance and the Examples suggest that we may be getting there, but not yet.

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.

© McDonnell Boehnen Hulbert & Berghoff LLP | Attorney Advertising

Written by:

McDonnell Boehnen Hulbert & Berghoff LLP

McDonnell Boehnen Hulbert & Berghoff 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.