WPI Wage Watch: Minimum Wage & Overtime Updates (March Edition)

by Littler
Contact

Never mind the Ides of March, for employers with tipped employees: beware the federal budget process. Presumably no one’s March Madness bracket had federal Fair Labor Standards Act (FLSA) amendments going to, let alone winning, D.C.’s “big dance.” How this Cinderella story plays out remains to be seen, so, during federal legislative half-time, we’ll take a quick look at the scores from other minimum wage, tips, and overtime games around the country.

FLSA Amendments (Tipped Employees Dunk & Baseball Players Get Dunked On): Within a 2,232-page budget bill were two FLSA amendments that took effect on March 23, 2018; the first concerned tips, and the second exempted certain employees from minimum wage and overtime requirements.

As amended, the FLSA prohibits employers from keeping employees’ tips for any purposes, including allowing managers or supervisors to keep any portion of these tips. The restriction applies regardless of whether a tip credit is claimed. If a violation occurs, an employer is liable for the amount of any tip credit taken and tips unlawfully kept, plus an equal amount in liquidated damages. Additionally, violators are subject to a civil penalty up to $1,100 per offense. Finally, the amendments provide that portions of the U.S. Department of Labor’s (DOL) 2011 final rule concerning tips “that are not addressed by section 3(m)” of the FLSA “have no further force or effect until any future action taken by the Administrator of the Wage and Hour Division.” It remains to be seen exactly what portions of the final rule will be impacted.

The Save America’s Pastime Act exempts from the FLSA’s minimum wage and overtime requirements any employee employed to play baseball who is compensated per a contract that provides for a weekly salary of not less than $290 for services performed during the league's championship season (excluding spring training and the off season). It does not matter how many hours the employee devotes to baseball-related activities.1

DOL Unveils PAID Program (The Unintentional Foul): The DOL unveiled its Payroll Audit Independent Determination (PAID) program, a six-month pilot program that allows certain employers to proactively address potential FLSA underpayments that are not connected to existing (or known threats of) litigation or administrative enforcement. In return for paying 100% of wages owed, a participating employer will not be required by the DOL to pay liquidated damages or civil monetary penalties.2

Montana Subs In Various Regulations: The Montana Department of Labor and Industry revised various wage and hour regulations. The revised rules permit voluntary tip pooling, discuss how service charges are distributed, and allow employers to deduct the percentage they pay on credit card tips when providing such tips to employees. Additionally, the Department aligned its independent contractor determination rules with similar workers’ compensation and unemployment rules.

Minimum Wage Will Not Change in Nevada (No Starting Lineup Changes): The Nevada Labor Commissioner announced that the state minimum wage will not change from July 1, 2018 through June 30, 2019 for employees who are offered qualified health benefits from their employers ($7.25 per hour) and employees who are not offered such benefits ($8.25 per hour).

California Supreme Court Will Hear Meal & Rest Period Case (Officials Are Reviewing the Play): The California Supreme Court accepted certified questions from the U.S. Court of Appeals for the Ninth Circuit. In doing so, the Court agreed to answer the following questions concerning California meal and rest period requirements: 1) Must employers of ambulance attendants working 24-hour shifts relieve attendants of all duties during rest breaks, including the duty to be available to respond to an emergency call if one arises during a rest period? 2) May such an employer require attendants to be available to respond to emergency calls during meal periods without a written agreement that contains an on-duty meal period revocation clause and, if such a clause is required, will a general at-will employment clause satisfy this requirement? 3) Do violations of meal period requirements, which require payment of a premium for each improper meal period, give rise to claims under California Labor Code sections 203 (waiting time penalty for final wages violation) and 226 (paystub requirements) if the employer does not include the premium in pay or paystubs?

Johnson County Iowa’s Unofficial Minimum Wage Increase (After the Buzzer – Does Not Count): Although in 2017 local minimum wage laws for private employers were preempted by state law, this did not stop the Johnson County Board of Supervisors from voting to “increase” the now-defunct (and inapplicable) local minimum wage rate from $10.10 to $10.27 per hour, effective July 1, 2018. As we previously noted, Johnson County vowed to continue to publish annual adjustments and urged employers to voluntarily pay the county’s minimum wage.

Redwood City Minimum Wage Ordinance Proposal (To Enact or Not to Enact, That Is The Question): A proposed minimum wage ordinance passed its first of two required readings by the City Council of Redwood City, California (Northern California – San Francisco Bay Area). Under the proposal, beginning January 1, 2019, the local minimum wage would be $13.50 per hour, increasing to $15.00 per hour on January 1, 2020, with annual adjustments occurring in 2021 and subsequent years (notably, the 2021 rate will factor in the cost-of-living increase for both 2019 and 2020). Tips cannot be used to pay the minimum wage. Employers cannot fund pay increases or respond to the law by reducing wages, increasing charges for parking, meals, uniforms, or other items, reducing non-wage benefits, or increasing an employee’s share of benefits (unless the prohibition is preempted by federal ERISA). The law’s requirement can be waived in a bona fide CBA if done explicitly, in clear and unambiguous terms, and prospectively; except in the property services industry (e.g., janitors, landscapers, groundskeepers, security guards). City-created posters must be conspicuously displayed and payroll records must be kept for three years. Discrimination or adverse action is prohibited, and a rebuttable presumption of retaliation exists if adverse action is taken within 120 days of a person exercising protected rights. The city can receive and investigate complaints, but employees also can file a private right of action.

That New Bill Smell (A Bill by Any Other Name Would Smell as Sweet): Numerous items were introduced since our last update, which are briefly highlighted below.

  • Minimum Wage: Minnesota SB 3108 would eliminate the minimum wage rate certain lodging facilities can pay employees working on a J visa (summer work travel exchange visitor). Minnesota SF 1901 would exempt minor league baseball players from state minimum wage and overtime requirements. However, reports suggest the author did not hit a home run during a committee hearing, so he benched (i.e., tabled) the bill. Puerto Rico PS 153 would, among other things, create a two-tier minimum wage system based upon whether a business grossed more or less than $1 million, gradually increase the minimum wage until it reaches $15.00 per hour, and require companies that gross less than $500,000 annually to pay 70% of the applicable minimum wage.
  • Tips: U.S. HR 5180, the Tip Income Protection (TIP) Act of 2018, was introduced but is unlikely to advance in light of the above-referenced FLSA tip amendments. Louisiana HB 126 would establish a statewide minimum wage, but only for tipped employees. Covered employees would be entitled to the full FLSA minimum wage (currently $7.25 per hour). The bill aims to essentially eliminate the tip credit for FLSA-covered employers. Minnesota SB 3108 would require all employers – regardless of size – to pay tipped employees at least $8.00 per hour so that when tips and the direct cash wages are combined, an employee averages at least $12.00 per hour.  It would also require that employees receive the full amount of a tip left by credit card.
  • Anti-Preemption: Louisiana SB 159 would repeal the state’s ban of local minimum wage laws. Wisconsin AB 998 seeks to repeal the ban against local minimum wage laws, but its chance of success appears slim given AB 748, an omnibus preemption bill that Governor Scott Walker (R) is expected to sign.3

What Passed at Least One House (Dignified, Sure, but Definitely Outside Verona): Arizona HCR 2028 aims to submit to voters a proposal to eliminate the rebuttable presumption that arises when adverse action is taken against an employee within 90 days of engaging in protected activity under the minimum wage law. Hawaii HB 1627 would eliminate the state labor department’s authority to issue rules allowing individuals whose earnings capacity are impaired by old age to be paid less than the minimum wage, as would SB 3023, which seeks to repeal the ability to pay less than the minimum wage to individuals with physical or mental disabilities.

What Passed at Least One Committee (Pun-Free Throw): Connecticut HB 5388, co-sponsored by seven state senators and 41 state representative and approved by the Joint Committee on Labor and Public Employees, seeks to increase the state minimum wage from $10.10 to $12.00 per hour, effective January 1, 2019, to $13.50 and $15.00 per hour in 2020 and 2021, respectively, with annual adjustments beginning in 2023. Louisiana SB 162 would establish a statewide minimum wage. Beginning January 1, 2019, the minimum wage would be $8.00 per hour, increasing to $8.50 per hour on January 1, 2020; unless the FLSA minimum wage is greater, in which case the state minimum wage will be the federal rate. However, if enacted, the law would not apply to student employees nor to tipped employees or agriculture employees covered by the FLSA. The bill includes a name-and-shame provision, requiring the Louisiana Workforce Commission to compile a list of employers that violate the law, the number of employees affected by violations, and the dollar amount of each violation, and to annually submit it to the Senate and House Committees on Labor and Industrial Relations and the governor. Louisiana SB 252 also seeks to enact a statewide minimum wage, but the provisions will be in the state constitution instead of a statute. It calls for the question to be put to voters in the November 2018 election. The minimum wage rates would generally be the same as in SB 162.  However, SB 252 would apply to employers with 50 or more full-time employees and would cover tipped employees while allowing employers to claim a tip credit that would be set by state labor officials.  Its effective date would be August 1.

Parting Is Such Sweet Sorrow: For at least this legislative session, we’ll have to live without the following bills. Delaware SB 10 sought to institute lock-step increases to the state minimum wage on October 1, 2017, 2018, 2019, and 2020. Louisiana HB 192 sought to establish, effective January 1, 2019, a statewide minimum wage of $15.00 per hour or the FLSA minimum wage (if greater), but was “involuntarily deferred in committee,” meaning it is highly unlikely it will again be considered. Maryland HB 974 would have increased the minimum salary (or fee) amount that must be paid to exempt executive, administrative, or professional employees from $455 to $900 per week, excluding board, lodging, or other facilities. Mississippi HB 1241 proposed to, among other things, prohibit local laws regulating or creating remedies for wage and hour disputes. Tennessee HB 2416 aimed to create a private right of action against employers violating a statute governing tip and service charge distribution.

We will continue to monitor and report on minimum wage and overtime developments as they occur.

 

Footnotes

1 The U.S. Court of Appeals for the Ninth Circuit asked parties involved in litigation under the FLSA involving minor league baseball players to file briefs concerning what impact the amendments have on the case.

2 For a more in-depth discussion of the PAID program, see Tammy McCutchen, Lee Schreter, and Meredith Schramm-Strosser, DOL Launches Payroll Audit Independent Determination (PAID) Program to Promote Self-Reporting and Early Resolution of Wage and Hour Claims, Littler ASAP (Mar. 7, 2018).

3 For a more in-depth discussion of Wisconsin AB 748, see Adam Tuzzo and Jonathan Levine, Still “Open for Business” – New Wisconsin Legislation to Preempt Most Local Employment Ordinances, Littler ASAP (Mar. 27, 2018).

 

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.

© Littler | Attorney Advertising

Written by:

Littler
Contact
more
less

Littler 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.