Trump Administration Drug Pricing Blueprint: Overview and Analysis

by Akin Gump Strauss Hauer & Feld LLP

Akin Gump Strauss Hauer & Feld LLP

[co-author: Sean M. Feely, Public Policy Specialist]

Key Points

  • The administration’s drug pricing Blueprint combines proposals that are already under way with new initiatives that may or may not be adopted.
  • Many of the more dramatic proposals would require federal rulemaking or even legislation to be implemented on a broad scale.
  • Stakeholders have the opportunity to provide feedback on the proposals by responding to a Request for Information, due by mid-July.


On Friday, May 11, President Donald Trump introduced his administration’s plan to address rising prescription drug prices: American Patients First: The Trump Administration Blueprint to Lower Drug Prices and Reduce Out-of-Pocket Costs.” He and Health & Human Services (HHS) Secretary Alex Azar identified key challenges facing the prescription drug market, including high list prices, limited negotiation tools, rising out-of-pocket costs, and foreign governments taking advantage of American pharmaceutical investment and innovation. This Alert describes the potential path forward for the various initiatives in the Blueprint, and it summarizes the key proposals. An addendum also identifies proposals for immediate action likely to require enactment of legislation for implementation.

Drug Pricing Plan: The Path Forward

The Blueprint combines new proposals with previously announced initiatives, some of which are already under way. The administration has the authority to advance some portions of the Blueprint through regulatory action, as noted in further detail below; other components might require congressional action, such as making significant changes to Medicaid drug coverage and empowering the Food and Drug Administration (FDA) to require disclosure of list prices in direct-to-consumer advertising. Given the tight congressional calendar and looming midterm elections, prospects for proposals that require legislation appear unlikely before November. However, a post-election, “lame duck” session of Congress could provide greater opportunity to advance these initiatives.

In other areas, the administration has more latitude to act on its own, through demonstration authority, rulemaking or other subregulatory policy development. For example, the Centers for Medicare and Medicaid Services (CMS) could provide Part D plans with greater flexibility to modify their formulary or benefit design midyear in response to drug price increases. FDA plans to issue guidance that would expedite generic versions of drugs and biosimiliars.

In public remarks on May 14, HHS Secretary Azar highlighted several specific activities planned for the near term. He indicated that CMS will be sending a letter to all Medicare Part D plan sponsors this week directing them to eliminate the “gag clauses” that prevent pharmacists from advising their patients of the most affordable options to purchase drugs. CMS also updated its drug-pricing dashboard today to increase the information available to consumers regarding increases in drug prices. In addition, Secretary Azar noted that HHS will begin work immediately to develop a new set of incentives on drug list prices, and CMS will be issuing a request for proposal “in short order” for an alternative system for purchasing Medicare Part B drugs through a Competitive Acquisition Program.

The administration is seeking feedback from stakeholders on a wide range of potential actions, providing opportunities to inform the administration’s thinking on how it can improve transparency and competition in the prescription drug market. A corresponding Request for Information (RFI) will be published in the Federal Register on May 16, and comments will be due by mid-July.

Below we have highlighted key aspects of the proposal across several programmatic areas, including opportunities to provide input.

Drug Pricing Plan: Key Highlights


The President’s FY 2019 Budget proposed a number of policies impacting drug spending in Medicare, including making changes to Part D plan formulary standards and protected classes; excluding manufacturer discounts when calculating out-of-pocket costs for beneficiaries in the so-called “donut hole”; and giving the HHS Secretary the authority to move certain Part B drugs into Part D.

The administration’s new Blueprint proposes a number of additional actions related to Medicare, many of which would strengthen the negotiating power of Part D prescription drug plans. The Blueprint proposes, for instance, to allow Part D plans to adjust formulary or benefit design during the benefit year to respond to price increases for sole-source generic drugs. This change could be implemented in next year’s rulemaking for the Prescription Drug Benefit and Medicare Advantage Programs. The Blueprint further proposes to allow high-cost drugs in Part D to be priced or covered differently based on their indication. It is uncertain whether CMS can implement this policy without congressional action.

Regarding physician-administered drugs, the Blueprint proposes that HHS prepare a report identifying opportunities to achieve savings by moving particular drugs or classes of drugs from Part B to Part D. CMS may need additional legislative authority to make this change, particularly if the program were to extend beyond a demonstration basis. Secretary Azar further emphasized in comments to reporters, “Moving the reimbursement of physician-administered drugs from Part B to Medicare Part D has the best promise of constraining the costs of very high priced medicines.”

In announcing the Blueprint, President Trump highlighted a specific proposal to block Part D pharmacy “gag clauses,” which prohibit pharmacists from telling patients when they could pay less out-of-pocket by not using insurance. Secretary Azar also mentioned this policy at a subsequent White House Press Briefing, suggesting that it is a top priority. With the goal of reducing list prices, the Blueprint also proposes to update CMS’ drug-spending dashboard to improve the transparency of Medicare and Medicaid prices and “hold drug makers accountable for their price increases.”

As stakeholders review the aforementioned Medicare policies, there will be additional questions regarding implementation and potential savings to the system. The Blueprint specifically seeks input regarding other Medicare proposals, including those related to value-based arrangements, long-term financing models and site neutrality across Part B drugs, as well as across drugs administered in both inpatient and outpatient settings.


The President’s FY 2019 Budget proposed to clarify how drugs are classified for Medicaid rebate purposes, clarify the Medicaid definition of “brand drug” and establish a new five-state Medicaid demonstration to apply private-sector practices to reduce drug prices. The new Blueprint further proposes to “develop proposals” related to the Affordable Care Act’s (ACA) maximum rebate provision, which potentially could increase manufacturers’ rebate obligations and/or impose new conditions for coverage under the Medicaid program.

The ACA previously limited the maximum federal rebate owed by a manufacturer for brand and generic drugs to 100 percent of the Average Manufacturer Price. The administration cites the risk of excessive price increases and cost-shifting by manufacturers as potential justifications for lifting the cap on rebates. The Blueprint also seeks input from stakeholders regarding a range of other potential initiatives to avoid underpricing of generic drugs, promote value-based and indication-based pricing and payment arrangements, and advance long-term financing models for high-cost drugs.

Most of these proposals likely would require that Congress amend the Medicaid statute. In addition, legislative and regulatory action may be required at the state level to align existing Medicaid program rules with new federal requirements. Particularly with respect to new payment and financing models, the Center for Medicare and Medicaid Innovation (CMMI) could play a leading role in advancing these objectives, and it represents an important target for engagement.


The Blueprint contains a number of proposed changes to the 340B Drug Pricing Program, which generally requires drug manufacturers to provide covered outpatient drugs at reduced prices to eligible health care providers—also known as “covered entities”—that serve vulnerable patient populations.

In its Fact Sheet, released simultaneously with the Blueprint, the administration indicated that some hospitals receiving 340B discounts “do not provide meaningful levels of charity care to low-income and vulnerable patients, ultimately pushing up drug prices for patients with private health insurance.” As part of its planned reforms, the administration is proposing to require hospitals paid under Medicare Part B to provide at least 1 percent of their patient costs in charity care in order to remain eligible for the 340B discount.

In the Blueprint, the administration invited public comment on a number of issues related to the 340B program, including how the growth of the 340B drug discount program has affected list prices. The most significant of these are proposals to change the definition of “patient” under the 340B program or to change the requirements governing covered entities contracting with pharmacies or registering off-site outpatient facilities (also known as “child sites”). Additionally, the administration is seeking comment on whether the current mechanisms for identifying and preventing duplicate 340B discounts and Medicaid drug rebates for the same drugs are sufficient, and on ideas on ways to improve the management and the integrity of claims for drugs provided to 340B patients in the overall insured market.

FDA Initiatives

Several aspects of the Blueprint feature proposals for FDA to facilitate drug industry competition and transparency. Some of the FDA-related initiatives leverage the agency’s existing Drug Competition Action Plan. For example, FDA will issue guidance addressing mechanisms that can be misused to delay or hinder the development of generic versions of a drug, such as shared system risk evaluation and mitigation strategies (REMS), and will release new policies to facilitate the development of biosimilars, including interchangeable biosimilars, under a forthcoming Biosimilar Action Plan. The Blueprint further directs FDA to evaluate issues relating to access to reference product samples.

One of the more notable proposals in the Blueprint would direct FDA to evaluate the mandatory inclusion of list prices in manufacturers’ direct-to-consumer advertising. This proposal raises a number of questions, including whether FDA has statutory authority to require this information. Finally, the Blueprint seeks input on whether Medicare and Medicaid should be able to adjust payment rates for various indications of a drug, and whether changes are required to the National Drug Code numbering system as used by CMS for price reporting.


According to the new Blueprint, the U.S. Trade Representative (USTR) will prioritize addressing unfair intellectual property and market access policies in trade agreements, so as to ensure that U.S. trading partners “contribute their fair share to innovation.” The USTR has often criticized foreign countries’ intellectual property policies, including through its annual Special 301 Report. For instance, in the just-released 2018 Special 301 Report, the USTR highlighted its Intellectual Property Rights (IPR) concerns with respect to Chile, Colombia, El Salvador, India and Malaysia for issuing, or threatening to issue, compulsory licenses on patented pharmaceuticals. These are used to drive down the cost of innovative drugs in these countries, either through allowing foreign companies to break existing patents in order to avoid paying patent licensing fees or using the threat of compulsory licenses to negotiate a very low price for the patented products. These tactics, according to the Blueprint, have resulted in U.S. consumers “subsidizing” the overseas low prices because they are being forced to pay higher prices here in the United States.

Pharmaceutical pricing has been a key focus of trade agreement negotiations in recent years. The World Trade Organization (WTO) Agreement on Trade-Related Aspects of Intellectual Property Rights (“TRIPS Agreement”), to which all WTO states are signatories, contains a number of provisions bearing directly on pharmaceuticals, including requirements to establish robust patent protection in all WTO member countries. Also, although it does not refer to the practice by name, the TRIPS Agreement does allow compulsory licensing under certain specific conditions in order to “strike a balance between promoting access to existing drugs and promoting research and development of new drugs,” according to a WTO factsheet. More direct pharmaceutical pricing obligations were subsequently added in the U.S.-Korea Free Trade Agreement, as well as in the initial draft of the Trans-Pacific Partnership Agreement.

Trade association response to the new Blueprint has thus far been mixed. Following President Trump’s announcement, BIO President and CEO Jim Greenwood issued a statement warning that, while the company “look[s] forward to working with the administration on solutions that help provide all patients access to prescription drugs with out-of-pocket costs they can afford,” they “have concerns that some of the ideas proposed today could, if adopted, hurt patient access to the medicines they need.”  Nonprofit organizations have also complained about the Blueprint, arguing that compulsory licensing and the lack of patent protection is not the reason that U.S. drug prices are so high.

In sum, there appears to be little support for the Blueprint’s rationale for linking IPR and drug prices, and legitimate concern for the administration’s proposed responses to these issues.

Proposals for Immediate Action Likely to Require Legislation

The following immediate actions proposed in the administration’s drug pricing plan are likely to require enactment of legislation for implementation. Page numbers correspond to the relevant sections of the Blueprint.

  • providing plans full flexibility to manage high cost drugs that do not provide Part D plans with rebates or negotiated fixed prices, including in the protected classes (p. 24)
  • evaluating options to allow high-cost drugs to be priced or covered differently in Part D based on their indication (p. 24)
  • taking steps to leverage the authority created by the Competitive Acquisition Program for Part B Drugs & Biologicals (pp. 24-25)
  • developing and implementing proposals related to the ACA’s Maximum Rebate Amount provision, which limits manufacturer rebates on brand and generic drugs in the Medicaid program to 100 percent of the Average Manufacturer Price (p. 25)
  • requiring the inclusion of list prices in prescription drug direct-to-consumer advertising (p. 25)
  • adopting legislative solutions to address the unfair disparity between the drug prices in America and other developed countries (p. 25).

Further proposals for which HHS is soliciting stakeholder feedback through the RFI process and other avenues also may require legislative action, depending on the scope of those initiatives.

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.

© Akin Gump Strauss Hauer & Feld LLP | Attorney Advertising

Written by:

Akin Gump Strauss Hauer & Feld LLP

Akin Gump Strauss Hauer & Feld 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.