The Top 5 Most Fashionable Intellectual Property Disputes To Walk This Year’s Runways at New York Fashion Week

Foley Hoag LLP - Trademark, Copyright & Unfair Competition

 

 

New York Fashion Week (NYFW) officially kicks off today, February 7, 2020, with a week’s worth of captivating runway shows from top designers. The timing, however, could not be worse, since the 92nd Academy Awards is airing on February 9th, dead smack in the middle of Fashion Week. Due to this scheduling snafu, designer Tom Ford, who styles top actresses walking the red carpet at the Oscars, will be a no-show in New York. Other notable no-shows include designers Jeremy Scott, Ralph Lauren, and Tommy Hilfiger, but as they say, the show must go on.

Each year during this time, I blog about intellectual property matters facing the fashion industry. I usually start my research by reviewing NYFW’s schedule. When reviewing this year’s runway schedule, I could not help but notice that many designers debuting fashions this year have been involved in a variety intellectual property disputes. Below is my rundown of the top 5 IP disputes that previously kept this year’s NYFW designers up at night!

1. Christian Siriano vs. Former Licensee

Christian Siriano is set to debut his Fall/Winter 2020 collection at NYFW. Siriano is the darling of fashion reality show Project Runway, which he won back in 2008. Shortly thereafter, Siriano launched his eponymous fashion collection. Known for his elegant and bold evening gowns and cocktail dresses, Siriano has dressed the likes of Sarah Jessica Parker and Kate Beckinsale. Michelle Obama even wore a Siriano design to the 2016 Democratic National Convention.

In 2018, Siriano was embroiled in a vicious trademark and breach of contract dispute with his former licensee M&A Imports, d/b/a Just Love. M&A Imports started the fight when it sued Siriano for $10 million for allegedly backing out of the parties’ trademark licensing agreement, which gave M&A Imports the right to manufacture affordable fashions bearing the federally- registered trademark CHRISTIAN SIRIANO. Siriano hit back with a lawsuit of his own, claiming that M&A Imports infringed his registered trademark when it allegedly used the CHRISTIAN SIRIANO trademark on low quality fashions that Siriano did not approved, in breach of the parties’ agreement. Siriano alleged that M&A Imports’ breach gave Siriano the right to terminate the agreement, and after termination, M&A Imports continued to sell unapproved dresses bearing his trademark.

All well-written trademark license agreements contain what are called “quality control” provisions. These provisions are important to any trademark license agreement, because they protect the trademark owner’s reputation and the goodwill residing in the owner’s trademark, by specifying certain minimum standards that the licensee must following, including approvals by the licensor of sample products bearing the licensor’s trademark. Exercising adequate quality control over a licensee also prevents consumers from receiving low-quality products bearing the licensor’s trademark. If a licensor does not exercise sufficient control over the quality of the goods and/or services bearing her trademark, the goodwill residing in the trademark can become tarnished, and the trademark can become vulnerable to attack or even be deemed abandoned.

Luckily for all of us fashion fans, Siriano and M&A Imports apparently settled their dispute, as the parties eventually agreed to dismiss the trademark infringement and the breach contract lawsuits, leaving Siriano to focus on designing beautiful dresses, like this one depicted below from Siriano’s specimen of use filed with the U.S. Patent and Trademark Office.

2. Paparazzi vs. Monse

Fashion label Monse will debut its Fall/Winter 2020 collection on day two of NYFW. Laura Kim and Fernando Garcia started Monse in 2015 to create clothes “that made [women] look like it took five minutes to get ready.” Today, Monse is a fan favorite among various celebrities, as displayed by many paparazzi photos of actresses like Sarah Jessica Parker and Jennifer Lopez wearing Monse’s latest designs.

Jumping at the opportunity to tout its celebrity following, Monse got into trouble last year after it decided to post this photo of Jennifer Lopez on its Instagram page wearing one of its dresses.

While Jennifer Lopez did not appear to object, Carlos Vila, the photographer who took the photo, was not happy. Vila filed a lawsuit against Monse before the U.S. District Court for the Southern District of New York, alleging copyright infringement, in violation of the U.S. Copyright Act.

With some exceptions, copyrights are generally owned by the people who create the works of expression. In the case of a photograph, the photographer usually owns the copyright in the photograph, and in order to publicly display a copy of that photograph, one usually needs permission from the photographer. According to Vila’s complaint, Monse failed to obtain permission, prompting Vila to file his complaint requesting statutory damages. Statutory damages are money damages that may be awarded by a judge or jury to a copyright owner in a copyright infringement suit under certain conditions. The amount awarded is established by statute (i.e., the Copyright Act), hence the name “statutory damages.” In general, if a defendant willfully infringes a registered copyright, then the court can award statutory damages as high as $150,000 per infringed work.

According to the case docket, Monse made an offer of judgment to Vila for $10,000, pursuant to Rule 68 of the Federal Rules of Civil Procedure. A Rule 68 offer of judgment is a written offer made by the defendant to resolve the plaintiff’s claim. If the plaintiff rejects or ignores the offer and then later earns a judgment less favorable than the offer, the defendant can recover its “costs” from the plaintiff. “Costs” usually include smaller litigation expenses, like transcript fees, court reporter fees, and filing fees. While “costs” usually do not include large expenses like attorney’s fees, when the statute relied upon by the plaintiff defines “costs” as including attorney’s fees, like the Copyright Act, then the plaintiff may be liable for the defendant’s attorney’s fees. Thus, Rule 68 offers of judgment can be very powerful for defendants accused of copyright infringement, particularly in cases where the court or jury are likely to determine that the plaintiff’s actual damages are small, or where there is no evidence of willful infringement that would increase the statutory damages award.

Thus, faced with the risk of paying Monse’s attorneys fees in the litigation, it appears from the case docket that Vila accepted Monse’s offer of judgment and the court entered a judgment against Monse for $10,000.

3. Longchamp vs. Home Goods and Accessory Retailers

French fashion company Longchamp’s Fall/Winter 2020 ready-to-wear line will be on full display at NYFW. Longchamp is known for creating a wide range of well-designed luxury accessories and clothing, including its well-know “Le Pliage” tote bag, which bears a distinctive trapezoid shape, leather trim and distinctive stitching. The look and style of the Le Pliage bag was registered before the PTO to Longchamp’s parent company S.A.S. Jean Cassegrain in 2005 as a design patent. Longchamp’s parent company also later registered the design with the PTO as a trademark in 2006, as shown below:


As discussed in my prior blog post here, in addition to protecting a designer’s name and logo, trademark law can also protect the design and appearance (known as the “trade dress”) of certain fashion products, including handbags (like Hermès’ Birkin bag), and shoes (like Converse’s Chuck Taylor sneakers). Trademark law can also protect fashion design elements, including prints and patterns (like Burberry’s plaid print), distinctive stitching (like the U-shaped jean pocket stitching owned by True Religion/Guru Denim), and even colors (like Christian Louboutin’s red bottom shoe soles). Trademark protection only extends to fashion designs that are non-functional and have achieved a certain level of consumers recognition (called “secondary meaning” or “acquired distinctiveness”). Although Longchamp’s 2005 design patent appears set to expire soon (design patents last for only 15 years), its trademark rights in the Le Pliage bag will last for as long as it continues to use that design in U.S. commerce.

In 2015, Longchamp sued houseware retailer Bed Bath & Beyond and accessory retailer Laila Rowe in NY federal district court, accusing the companies of selling knockoff handbags and coin purses that allegedly looked like the Le Pliage bag. Longchamp alleged in the complaint that Bed Bath & Beyond and Laila Rowe committed patent infringement and trademark infringement, which allegedly caused Longchamp to lose sales in excess of $1 million.

Based on the court docket, it appears that the parties eventually settled their dispute.

4. Naeem Khan vs. Clothing Retailer

Naeem Khan is one of my favorite designers at this year’s NYFW. Kahn has dressed the likes of Michelle Obama and Kate Middleton, and is known for intricate, ornate and colorful patterns and designs. While Khan was previously in the press for refusing to dress first lady Melania Trump, he also made some heads turn when he posted a message on Facebook accusing J. Crew of copying one of his dress print patterns.

As explained in my prior post, prints and patterns can be protected by copyright, and in some instances, by trademark law. It doesn’t appear that Khan took any action against J. Crew, and based on his post, maybe he decided to take J. Crew’s design as a compliment.

5. Twitter Users vs. Michael Kors

Michael Kors is expected to debut his 2020 Fall/Winter collection of ready-to-wear fashions on the last day of NYFW. At last year’s NYFW, Kors debuted his spring and summer collection, which included styles that reminded many of designs and prints that are associated with hoodies worn by Mexican and U.S. Latinx youth called “jergas” or “Baja jackets.” According to Chimayoweavers.com, jergas are known as a “very old part of our tradition, dating back to the Spanish Colonial era. It is a simple twill weave, either a straight twill or a diamond twill called ojo de perdiz. Historically, this was the utilitarian fabric of New Mexico, used to wrap up bundles as you might use a tarp[.]”

Many Twitter users recognized the designs and were not happy with Michael Kors’ use of the jerga style and prints in his runway show, accusing the designer of cultural appropriation.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Cultural appropriation is the co-opting of intellectual property, cultural expressions, traditional knowledge or artifacts from another’s culture (usually a minority or indigenous group) without their input, consent, credit, or compensation. As I discussed in my prior post on cultural and intellectual property appropriation in the fashion industry, traditional cultural expressions raise particular legal and policy questions in intellectual property law. Traditional cultural prints may be exclusively owned by a particular organization or community under U.S. copyright law (so long as they are original, creative, and physically or conceptually separable from the function of the article) or trademark law (provided they are nonfunctional, distinctive source identifiers). Some countries also have special legislation for the protection of traditional cultural expressions.

In the case of Michael Kors, because jergas are known to be worn mostly by working class youth in Mexico, using them on NYFW’s runway as high fashion, and allegedly without crediting the people who originated the design, was seen as a smack in the face to certain members of the Mexican and the Latinx communities.

Brand owners should use special care when adopting prints, trademarks, product designs, packaging, and advertising campaigns that might appear to represent a cultural expression, and should consider these issues as part of their intellectual property clearance procedures and consult with legal counsel, particularly for important designs that may be part of a global ad campaign or runway show.

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.

© Foley Hoag LLP - Trademark, Copyright & Unfair Competition | Attorney Advertising

Written by:

Foley Hoag LLP - Trademark, Copyright & Unfair Competition
Contact
more
less

Foley Hoag LLP - Trademark, Copyright & Unfair Competition on:

Readers' Choice 2017
Reporters on Deadline

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

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

JD Supra Privacy Policy

Updated: May 25, 2018:

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

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

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

Collection of Information

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

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

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

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

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

How do we use this information?

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

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

How is your information shared?

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

How We Protect Your Information

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

Children's Information

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

Links to Other Websites

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

Information for EU and Swiss Residents

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

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

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

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

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

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

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

California Privacy Rights

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

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

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

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

Access/Correct/Update/Delete Personal Information

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

Changes in Our Privacy Policy

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

Contacting JD Supra

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

JD Supra Cookie Guide

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

How We Use Cookies and Other Tracking Technologies

We use cookies and other tracking technologies to:

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

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

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

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

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

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

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

Controlling and Deleting Cookies

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

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

Updates to This Policy

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

Contacting JD Supra

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

- hide

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