Update on Significant DOT, FAA, and Other Federal Agencies’ Aviation-Related Regulatory Actions - July 2017

Cozen O'Connor

Cozen O'Connor

This edition of the Cozen O’Connor Aviation Regulatory Update discusses the latest FAA reauthorization bills, the Department of Homeland Security’s enhanced aviation security measures, the DOT Inspector General’s audit reports regarding the FAA’s oversight of suspected unapproved parts and check pilot qualifications, the Department of Commerce’s investigations regarding aircraft imports from Canada, and the latest DOT and FAA enforcement actions.

Department of Homeland Security

DHS Enhances Aviation Security Measures for All Commercial Flights to the United States

The Department of Homeland Security (DHS) issued a release and fact sheet on new aviation enhanced security measures. The measures include enhanced passenger screening and heightened screening of personal electronic devices that will be conducted at 280 international airports that serve as the last point of departure for commercial flights to the U.S. In DHS Secretary John F. Kelly’s remarks on the new measures, he stated that “it is time to raise the global baseline of aviation security.”

Department of Transportation


DOT Inspector General Issues Audit Report Critical of FAA’s Oversight of Unapproved Parts

DOT’s Office of the Inspector General (“OIG”) issued an audit report that criticized the FAA’s oversight of suspected unapproved aircraft parts. OIG found that recordkeeping weaknesses and a lack of management control hindered the effectiveness of the FAA’s ability to identify and remove suspected unapproved parts from the aviation industry. The report stated that the FAA’s unapproved parts database contains numerous errors and the FAA’s hotline personnel are not adequately trained on how to record suspected unapproved parts-specific information. The report also stated that FAA inspectors did not uniformly follow the FAA’s established guidelines when performing unapproved parts investigations, which results in “varying and inconsistent results.” OIG also contended that the FAA’s risk-based oversight system is unable to incorporate suspected unapproved parts as a risk indicator for aviation manufacturers. The report also criticized the FAA’s inability to consistently implement procedures for notifying the industry about unapproved parts and ensuring that operators destroy or remove unapproved parts from the aviation supply chain. OIG issued a number of recommendations to improve FAA oversight of suspected unapproved parts, including providing better training to hotline employees on how to accurately record data about suspected unapproved parts in the FAA's database; development of improved management control to ensure inspectors follow guidance when conducting unapproved parts investigations; incorporating a “risk indicator” for manufacturers where unapproved parts have been found as part of the FAA’s risk-based oversight system; development of a management control to ensure inspectors require operators to remove unapproved parts from use and their inventories; and requiring the FAA to forward all confirmed suspected unapproved parts cases to federal law enforcement agencies, whether or not criminal activity is suspected.

DOT Inspector General Criticizes FAA’s Regulatory Oversight of Check Pilots

OIG also issued an audit report contending that the FAA’s processes for approving air carrier check pilots and aircrew program designees (APDs) to act on behalf of the FAA to certificate pilots and oversee check pilots are “insufficient to ensure that required training and observations for check pilots and APDs are completed or documented.” The report found that in many cases, FAA inspectors failed to verify check pilot applicants completed mandatory training and had been observed by an FAA inspector. OIG’s audit also found that a number of check pilots did not receive any recurring training. In addition, the report stated that the FAA is “not ensuring that carriers are consistently meeting check pilot requirements.” The OIG’s report recommended that the FAA improve its training for FAA inspectors to increase the verification of check pilot qualifications; develop guidelines requiring inspectors or their designees to verify that check pilots have met training requirements prior to their performing “recurrent observations;” change requirements for inspectors to ensure that check pilot records are regularly evaluated to assess the accuracy of air carrier training; and establish a training program on approving and overseeing check pilots under Advanced Qualification Programs for inspectors assigned to airlines using those programs.


Delta Air Lines Assessed $120,000 in Civil Penalties for Animal Reporting Violations

DOT issued a consent order against Delta Air Lines for alleged failure to file accurate animal reporting statistics with DOT’s Aviation Consumer Protection Division (ACPD). On January 15, 2016, Delta reported that it transported 98,779 animals during 2015. After an inquiry by the ACPD into the methodology used to calculate the total number of animals reported during a calendar year, Delta stated that its first calculation was incorrect and that it actually transported 159,747 animals during 2015. After an investigation by DOT’s Office of Aviation Enforcement and Proceedings, Delta changed its animal reporting numbers a third time stating that it transported 96,630 animals in 2015. Delta explained that the miscalculations were part of protocols and methodologies it had to develop to meet DOT’s new reporting requirement. DOT found that Delta violated 49 U.S.C. § 41721 and 14 C.F.R. Part 235, and assessed Delta $120,000 in civil penalties. Delta was ordered to pay $60,000 in civil penalties within 30 days, with the remaining $60,000 due and payable only if, within one year of the service date of the consent order, Delta violates the order’s cease and desist or penalty payment provisions.

Federal Aviation Administration


FAA Proposes $435,000 Civil Penalty Against United Airlines for Alleged Aircraft Airworthiness Violation

The FAA issued a release proposing the assessment of $435,000 in civil penalties against United Airlines for allegedly operating a Boeing 787 aircraft in a non-airworthy condition. The FAA alleges that United failed to perform a required inspection of a fuel pump pressure switch it replaced prior to returning the aircraft to service. The FAA stated that the carrier operated the aircraft on 23 passenger flights before performing the required inspection on June 28, 2014, with two of those flights allegedly occurring after the FAA had notified United that it had not performed the required inspection.

FAA Assesses Civil Penalties Against Terrazzo USA & Associates, Inc. for Alleged Hazardous Materials Violations

Terrazzo USA & Associates, Inc. of McLoud, Oklahoma, was assessed $63,000 in civil penalties for allegedly violating hazardous materials regulations. The FAA issued a release alleging that on June 23, 2016, Terrazzo USA tendered a box containing a corrosive liquid to UPS to be transported by air. According to the FAA, the box was not accompanied by required shipping papers or emergency response information. Furthermore, the FAA stated that the package was not properly marked, was not in the “proper condition” to transport the hazardous materials, and the company failed to ensure its employees had been properly trained to handle hazardous materials.

FAA Assesses Civil Penalty Against Gladwin Paint Company for Alleged Hazardous Materials Violations

Gladwin Paint Company of Arlington, Texas, was assessed a $63,000 civil penalty for alleged hazardous materials violations, according to a release issued by the FAA. The FAA alleges that Gladwin provided a box of flammable paint to FedEx for shipment by air from Arlington to Abilene, Texas. According to the FAA, the shipment was not accompanied by proper shipping papers and was not properly marked, labeled, or packaged to prevent the release of hazardous materials. The FAA also alleges that Gladwin failed to ensure its employees had been properly trained to handle hazardous materials and include emergency response information with the shipment.

Department of Commerce International Trade Administration

ITA Initiates “Less-Than-Fair-Value” and “Countervailing Duty” Investigations of Aircraft Imports from Canada

The Department of Commerce’s International Trade Administration (ITA) issued a notice initiating an investigation of the importation into the United States of Bombardier 100- to 150-seat aircraft from Canada in response to an anti-dumping petition filed by The Boeing Company. Boeing’s petition alleges that the aircraft are being or will be sold in the United States at a less-than-fair-value within the meaning of section 731 of the Tariff Act of 1930, as amended. In addition, ITA issued a notice initiating a “Countervailing Duty Investigation” regarding the aircraft in response to Boeing’s petition. Boeing’s petition also alleges that the Canadian government, the provincial government of Quebec, and the government of the United Kingdom are providing “countervailable subsidies” for the imported aircraft and that such imports were “threatening material injury” to U.S. industry. Comments on the scope of the investigations were due June 6, 2017, and rebuttal comments were due June 16, 2017.

Federal Communications Commission

FCC Proposes to Amend Rules Governing Satellite Earth Stations Mounted on Aircraft

The Federal Communications Commission published a notice of proposed rulemaking that would amend rules governing earth stations in motion (ESIMs) used to provide satellite-based services on aircraft and other transportation modes communicating with geostationary satellite orbit (GSO), fixed-satellite service (FSS) satellite systems. The proposed rule would eliminate duplicative rules that apply to ESIMs and require that ESIMs meet the same requirements as fixed and temporary fixed earth stations. The NPRM would also reorganize and consolidate rules, including technical, operational, and application rules for Earth Stations Aboard Aircraft (ESAAs). The proposed rules would also allow the operation of ESIMs in the conventional “Ka-band” by applying to ESIMs communicating with GSO FSS space stations operating in 18.3–18.8 GHz and 19.7–20.2 GHz (space-to-Earth), and 28.35–28.6 GHz and 29.25–30.0 GHz (Earth-to-space) frequency bands, resulting in the promotion of “innovative and flexible use of satellite technology” and “new opportunities for a variety of uses.” Comments on the proposed rule are due July 31, 2017, with reply comments due August 30, 2017.

Government Accountability Office

GAO Issues Report on Air Carriers' Disability-Training Programs and DOT Oversight

The Government Accountability Office (GAO) issued a report on its review of 12 U.S. and foreign airlines’ disabled passenger-related training programs and DOT oversight of airlines’ compliance with the Air Carrier Access Act (ACAA) and DOT’s disabled passenger regulations under 14 C.F.R. Part 382. GAO found that each airline it reviewed was able to demonstrate that it has in place sufficient training programs for its employees and contractors who interact with disabled passengers. GAO's review also found that some airlines have voluntarily implemented quality assurance programs to “improve and sustain their disability training programs' performance.” GAO also stated that some airlines have created “disability boards,” which serve as forums for increasing awareness among airline employees regarding disability-related issues, even though this is not required by the ACAA or DOT regulations. GAO reviewed DOT’s oversight methods for ensuring ACAA compliance by airlines, including its analysis of disabled passenger complaint data, regulatory compliance inspections, and enforcement actions and the imposition of civil penalties for violations. The report found that DOT analyzes passenger complaints for trends and patterns and for “potential egregious violations.” DOT conducts compliance reviews at airline headquarters, including compliance with disability-related rules. GAO stated that since 2008, DOT has conducted 38 reviews at airline headquarters, resulting in 12 ACAA violations. In addition, DOT has initiated compliance audits of airlines at a number of airports.

Congressional Action Impacting Aviation

House and Senate Mark-Up FAA Reauthorization Bills Featuring Air Traffic Control Reorganization and Consumer Protection Provisions

The U.S. Senate and House of Representatives unveiled their long-awaited FAA reauthorization bills. The Senate bill, S. 1405, would reauthorize FAA appropriations through fiscal year 2021, make limited changes to Passenger Facility Charges (PFCs), and require airlines and ticket agents to disclose their fees for certain services in a standardized format and provide automated refunds to passengers for any ancillary service fees paid for services that were not received. The bill would also prohibit passengers who were involuntarily bumped from being removed from aircraft except for safety, security or health reasons. In addition, the bill would amend family assistance plan requirements for families of victims of air accidents and change certain flight attendant duty time and rest period rules. The bill would also require the FAA to order aircraft manufacturers to install secondary cockpit barriers on new aircraft manufactured for delivery to U.S. Part 121 air carriers.

The House bill, H.R. 2997, reauthorizes funding for FAA programs through fiscal year 2023 and includes House Transportation Committee Chairman Bill Shuster’s (R-Pa.) proposal to create a private, non-profit organization to oversee the nation’s air traffic control system. The ‘‘21st Century Aviation Innovation, Reform, and Reauthorization Act’’ or the ‘‘21st Century AIRR Act’’ would transfer air traffic control operations currently provided by the FAA to a separate not-for-profit corporate entity, the “American Air Navigation Services Corporation,” which would be governed by a 13-member board of directors comprised of a CEO, two directors appointed by DOT, and one director nominated by each the following groups: 1) passenger air carriers; 2) cargo air carriers; 3) regional air carriers; 4) general aviation; 5) business aviation; 6) air traffic controllers; 7) airports; and 8) commercial pilots, plus two directors nominated and selected by the other directors. The corporation would assume operational control of air traffic services from the FAA on October 1, 2020. The bill also contains a number of consumer protection provisions. The bill would: 1) prohibit the use of cell phones during flight; 2) clarify that airlines and ticket agents may separately disclose government-imposed taxes and fees in fare advertisements as long as the total cost of the air transportation is also provided; 3) require that fare quotations include the disclosure of baggage fees that may apply; 4) prohibit the bumping of airline passengers already onboard an aircraft except for emergency or safety-related reasons; 5) require airlines to provide additional information on their websites’ homepages regarding how consumers can submit complaints to DOT and the airline; 6) require airlines to provide information on the amenities and accommodations that would be provided by the airline to passengers in the event of a “widespread disruption” in service; and 7) clarify compensation requirements for passengers who are involuntarily denied boarding due to an oversold flight. The bill would also substantially increase spending on the Essential Air Service Program.

Both bills were considered and passed by their respective committees. The House Transportation and Infrastructure Committee held its markup on June 27, 2017, and passed the bill by a vote of 32-25. The Senate Commerce, Science and Transportation Committee held a markup on June 28, 2017, and passed its bill by voice vote. Both Committee chairmen have indicated a desire to have the bills considered by the full House and Senate before Congress recesses for the August break on July 28. With only 15 days in session before the break, no formal schedule for consideration has been set. If both bills pass their respective bodies, a conference to reconcile the two bills would be held later this summer.


Written by:

Cozen O'Connor

Cozen O'Connor 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.