JONES DAY TALKS®: Women in IP — Protecting Trade Secrets in Remote-Work Situations
In this edition of Jones Day's Women in IP series, partners Rebecca Swindells and Meredith Wilkes explore the challenges of protecting trade secrets when employees are working at home or other locations outside the office. They discuss the obligations incumbent on employers to protect trade secrets, the risks related to remote employees that should be addressed, and the legal remedies available when trade secrets are compromised.
Podcast: Play in new window | Download
SUBSCRIBE TO JONES DAY TALKS®
Subscribe on Apple Podcasts
Subscribe on Android
Subscribe on Google Play
Subscribe on Stitcher
Read the full transcript below:
Dave Dalton:
The modern day work arrangement is constantly changing. Employees have more flexibility than ever to work remotely, either at home, or in other non-traditional arrangements. But when employees have access to business critical information in the form of trade secrets, numerous issues are raised. Jones Day's Rebecca Swindells explains these concerns in her article in the June, 2020 edition of the World Intellectual Property Review. To file that article, which you can find at jonesday.com, in this edition of our Women in IP series, Rebecca and Jones Day partner, Meredith Wilkes, discuss responsibilities employees have with regard to protecting trade secrets, the risk presented relative to trade secret protection when employees are working remotely, and how companies can effectively manage those risks. I'm Dave Dalton, you're listening to Jones Day Talks.
Dave Dalton:
Based in London, Jones Day partner, Rebecca Swindells, has extensive experience in a wide range of intellectual property issues, including copyright, design and database rights, trademarks, domain names, and confidential information. She has a particular sector focus on technology, media and telecommunications, or TMT, as well as retail and financial services. Meredith Wilkes, a Cleveland based partner, co-leads Jones Day's global Trademarks, Unfair Competition and Copyrights group. She is a lead trial lawyer that has focused on high stakes trademark, trade dress, trade secret, false advertising, and design patent litigation matters for global brands and federal and state courts throughout the United States for more than 20 years. She also chairs Jones Day's Women in IP initiative. Rebecca and Meredith, thanks for being here today.
Meredith Wilkes:
Thanks for having us Dave.
Dave Dalton:
Interesting topic, and what we're going to do today is explore some issues that were brought out in a June, 2020 article published in the World Intellectual Property Review, that was written by Rebecca with help from trainee Andrew Aistrup out of the London office. So we're talking about protecting trade secrets at home, and I wouldn't quite file this under unintended consequences, or unexpected consequences, but when things change issues pop up that you're not always aware of, or that maybe you didn't plan for. And certainly in this era where people are working remotely away from their conventional business surroundings, their office, whatever, at home, offsite, wherever it is, there are some issues that need to be addressed that traditionally weren't a factor. So let's talk about protecting trade secrets at home. So let's get into this, we'll start with Rebecca. Rebecca, before we get into the specifics of how one protects trade secrets when employees are working away from the office, talk about the responsibilities that the owner has pertaining to perpetuity of a trade secret. What does the owner of the trade secret need to do going in to make sure that it's protected adequately?
Rebecca Swindells:
Sure. So basically there are three things you need to do to prove that you have a trade secret to be able to protect it in the UK and the EU. First, the information you are seeking to protect must be secret. Sounds obvious, but it's amazing how many businesses fail at this first hurdle. Basically you need to show that the information is not generally known within the industry, and not generally accessible to people outside of your organization. So it's got to be confidential in nature. And secondly, the information must have commercial value due to its secrecy. So it could be that it gives the business a competitive advantage over other businesses. For instance, it could be some improves efficiency in a manufacturing process, or a higher quality product, or a product or service offering that is unique in the market. And then last but not least, you need to show that you've taken reasonable steps to retain the confidentiality of the information. So to keep it secret.
Rebecca Swindells:
And in figuring out what is reasonable, it's all about what is proportionate, thinking about the scale and value of the trade secrets in question. So for a large organization, which has many trade secrets, that might involve auditing, and then categorizing different types of information within the business from say relatively low value to what I'd call crown jewels status, and then putting appropriate measures in accordingly. So you might restrict access to the crown jewels type information to only a handful of key individuals on a need-to-know basis. And then you would want to closely monitor their access to, and disclosure of that information.
Rebecca Swindells:
Now it sounds like quite a lot to do, and quite a hard test to satisfy, but if you get it right, the bonus is that you can get perpetual protection of the information for as long as it's kept secret. And that's different from say patent protection, or some other IP rights protection, where it tends to be for a finite number of years. And that longevity of protection of trade secrets can really give a business an edge. The one that we always use as an example is the Coca-Cola recipe, but equally it could apply to algorithms for other valuable information.
Dave Dalton:
Rebecca, do companies get it wrong sometimes, and they probably do, which is why they call you. But I guess specifically what I'm wondering is, do sometimes companies underestimate the value of what they have? Like this should be better protected, that's almost a crown jewel type trade secret you're talking about. Is this something that's easy for a client to underestimate?
Rebecca Swindells:
I think that happens a lot. It depends on the industry. Obviously some businesses will be very sophisticated in knowing what they're dealing with and its value, but for many of our clients, you're absolutely right. They do underestimate the information that they have. And I think often it pays dividends to sit back and look at what the information the business has, maybe getting somebody to audit it, and then to take the right procedures, and put the right systems in place to protect it.
Dave Dalton:
Sure. Sure. Let's swing over to Meredith Wilkes for a second, and talk about what goes on the United States and other jurisdictions. Surely there are measures in place which demand a similar degree of responsibility as what Rebecca has described in the UK. Is that correct?
Meredith Wilkes:
Well, that's absolutely right, Dave. Similar to the standards that Rebecca mentioned, in the United States in particular, to be afforded trade secret protection, a trade secret owner is going to have to demonstrate that this secret has independent economic value from not being generally known, and that incorporates reasonable efforts to keep the confidential information confidential, and it's a facts and circumstances analysis. And so the longer we continue in the remote working and remote learning environment, I think it would be reasonable for trade secret owners to expect the barrier and the burdens go higher and higher and higher.
Meredith Wilkes:
One of the areas that we see the most questioning around, and the greatest inquiry from our clients, deals with vulnerabilities in security protocols. Do we have sufficient security around the crown jewels that Rebecca mentioned? And the other area that we're seeing a lot of questions around, and that's getting a lot of, I think hype and coverage in the media right now, is data access. And are we protecting access adequately under the circumstances, particularly in view of the fact that you've got so many people working on the internet, and using internet based platforms when before maybe they were physically present in place in the workplace? And so those are the two vulnerabilities that we're seeing right now, is security protocols, and are we putting enough protection around that information?
Dave Dalton:
Had you seen an uptick in these sorts of problems even before 2020 with everything that's going on, and more people working remotely, had this been a trend anyway, or was it exacerbated by recent events?
Meredith Wilkes:
Definitely a trend. Folks have been starting to move away from physical offices for a long time, and people have been taking more calm with them, accessing their businesses remotely. And so we've seen increased attention on appropriate protocols and, of course, data security breaches and things like that. But particularly when you take your entire workforce in place of them working remotely for a period of time, that inquiries and the questions really become increased. And so we're seeing it exacerbated right now because of the remote working situation and remote access.
Meredith Wilkes:
And I think it will continue. We don't know exactly when everybody's going to be physically present back in their workplace, some people already are, some people aren't. And with every new event comes new opportunities. So maybe we'll see more people starting to make the norm remote operations instead of being physically present in an office, or going to hybrid situations where half the time you're physically present in an office, half the time you're not. And so with all those changes come new challenges, or our clients to be thinking about, and hopefully we're right there with them to help them figure out how to best meet those challenges.
Dave Dalton:
Sure. And I sense a steep learning curve coming because I don't think things will ...
Meredith Wilkes:
I think so.
Dave Dalton:
... slow down anytime soon. Let's go back to Rebecca for a second. Hey Rebecca, by the way, Tom Kondilas and I were talking before, this is your first Jones Day Talks podcast, is that correct?
Rebecca Swindells:
It is. Yes.
Dave Dalton:
Well, is it exceeding what I'm sure where your locked expectations coming in, are you enjoying it?
Rebecca Swindells:
Well, I've listened to a lot of them that have been put out by Jones Day before. And so it's very exciting to be part of it. Yeah, they're very, very good fun.
Dave Dalton:
Wow. Well, I wasn't fishing for a compliment. I was trying to be funny as usual, I wasn't. So anyway, but thanks for the kind words. And Meredith gave us a great segue in to talking about what we're really here to get to today. Let's talk about some of the risks presented relative to trade secret protection when employees are working remotely. They're not in the office anymore. They're not in the plant, the factory, the lab, whatever, they're off-site. So what are we risking here? What do we look out for?
Rebecca Swindells:
Yeah, sure. As Meredith just pointed out, the remote working environment presents challenges of its own, which will inevitably increase the risk of unauthorized disclosure of trade secrets, whether it's innocent, inadvertent, or intentional, because you just don't have the usual checks and balances that you would have in place in the physical working environment. First of all there's less visibility over communications from employees to external third parties, or even to other people within the organization.
Rebecca Swindells:
And remote working is inevitably going to mean the other members of the household, or other people present wherever the employee happens to be working, may have access to their confidential information, particularly if documents are not being stored and disposed of carefully. And then you have issues such as the use of non-work devices, laptops, mobile phones, or employees using public, or unsecured networks, all of which will increase the risk of a trade secrets breach. And then coupled with all these remote working issues, you've got the current economic downturn resulting from COVID-19, which is just going to exacerbate the risk.
Rebecca Swindells:
We've seen globally, many businesses have been taking tough decisions to furlough employees, or terminate their contracts. Others have been putting their workforce on reduced hours. So I think generally there's less engagement with the workforce, and letting go of staff remotely means that the usual debriefs, or security checks that would normally take place in-person at the business's premises are just not happening. And on top of that, you've got some disgruntled employees who may be desperate to find new jobs, and may unfortunately be tempted to take know-how from their employer.
Dave Dalton:
Mm-hmm (affirmative). Well, you touched on something a second ago that I'd like to follow up on. You said it can be an innocent breach trade secret gets out with no bad intentions. If you had to guess, is that the majority of trade secret losses, if that's the right word? Is it just, someone was careless, or they weren't following the protocols, or as an accidental, it was innocent as you say, versus if someone's maliciously trying to damage a former employee, or go off and get rogue. How does that break down? Are most of them innocent as you'd put it?
Rebecca Swindells:
Most trade secrets cases are going to involve an employee deliberately taking with them confidential information and joining a competitor. That is absolutely the standard case. I think with remote working issue, we're looking at a lot of risks that it presents to clients, including cyber security risks, data breaches, and trade secrets breaches. So in a way, businesses I think need to look at that in a round and to be tightening up all of their security measures to ensure that these innocent inadvertent disclosures don't happen. But when you're talking about high value trade secrets claims, they will almost always involve an intentional breach by an employee.
Dave Dalton:
Okay. Well, that's disappointing to hear for certain, obviously we believe you, and it's sorry to hear, but it also gives us another good segue in what I wanted to ask Meredith about, and Rebecca jump in. So it's obvious that managing these risks is so critical to a company's successful operations. Meredith talk about some of the safeguards that should be considered when guarding against the activities that Rebecca just brought up.
Meredith Wilkes:
Wow. Yeah. And there's a really, really, really long answer to that one. So for sure, if I get to jump in on this, Rebecca is exactly right, in times of economic downturn and workforce displacement, whether it's some mobility layoff furloughs, there is an increased and heightened risk of trade secret misappropriation. We know from studying the data that the costs in that respect are significant of trade secrets in the United States costs companies between one and 3% of the US GDP every single year. So we're talking about something pretty substantial here, and Rebecca referred to it as the crown jewels. And that's how we talk to clients about this.
Meredith Wilkes:
And so when I'm talking to clients about ways in which to protect trade secrets, and ways in which to fortify the surroundings, I go back to medieval castle type of analogy and say, when we were building castles hundreds and hundreds and hundreds of years ago, they made them at a really, really thick stone, and they perched them high on a hill to prevent people from being able to gain access, but they didn't just do that. They had these really big, huge, thick doors that were guarded by people outside. And there were fences and walls around the castle. And more than that, then there was a moat, and in front of the moat, that was also guarded.
Meredith Wilkes:
So we're talking about layers and layers and layers of protection around these crown jewels. And so I break it down into three different buckets. I break it down into an education bucket, I break it down to an access bucket. And then I break it down into a walk the talk type of bucket. And under the education bucket, I say, all right, we've got to educate our workforce. We've got to educate our employees about the trade secrets. And that starts on day one that we have a policy about trade secrets, and that we keep confidential information confidential, and employees sign off on it. They sign off on it in employee handbook, or they sign off on it through a nondisclosure agreement. And this is where, in the United States in particular, because I'm a US lawyer, so that's what I can talk about. Having the help of our labor team and our employment lawyers becomes really critical because what you can ask employees to sign in different states varies dramatically.
Meredith Wilkes:
So you ask folks to sign non-disclosure agreements, confidentiality agreements. We explain to employees why the information has to remain confidential, and we mark it confidential. We talk to employees about what data security protocols are in place, how they're enforced, and most importantly, how to report any type of breach of data security. So, that's the starting point with the education bucket, but then we talk about limiting access. And Rebecca talked about this as well. We talked about limiting access, both physically and virtually. And since we're talking about the remote working environment, I'll limit my comments right now to the limiting the virtual access, and Rebecca explains this in detail in her article.
Meredith Wilkes:
What we're trying to do here is reduce the number of people accessing. And then we also want to know who's accessing, and what they're accessing. So we want to make sure that we've got a document management system where the secrets are centrally located and can't be exported anywhere else, and we know who's accessing it. We want to make sure in this virtual environment that we're using a secure VPN network, that we have secure FTP file transfers that are encrypted so that they can't just be accessed by anyone out on the internet. We want to make sure that we're able to prevent download of the trade secret information to thumb drives, or other types of remote devices.
Meredith Wilkes:
We want to have a system in place where we're monitoring access of these files, some clients, and again, we have to be careful on different, with state law, and in Europe with privacy concerns about what we're monitoring with respect to employees, for sure. But we want to be monitoring who's accessing files, and some companies have alerts in place when large volumes of information are being accessed, being removed, being sent to a different storage device. Another thing that we're talking to clients about a lot right now is the platforms that employees are using. We want to make sure that we're vetting those to make sure that those platforms, whether it's a Google platform, a Zoom platform, a WebEx platform, whatever those different platforms are, we want to make sure that they're the proper security protocols in place there as well. So that we're limiting, again, who can access this information in the virtual world.
Meredith Wilkes:
And then, of course, the third bucket is walking the talk, and that's enforcing. Rebecca talked about the volume of trade secret cases that we see are the former employee taking information to a competitor. And it's an unfortunate situation, but it does happen, and that's when we get involved. Maybe they're not calling us when the innocent breaches occur, but when we onboard employees, we want to make sure we're not taking anyone who's tainted, or has trade secret information with them. So we counsel our clients on how to make sure we're not bringing in employees who have trade secrets, and that we're not using somebody else's trade secrets. We enforce NDAs, we monitor compliance, and then, of course, because there's that obligation to be reasonable under the circumstances, we update manuals and procedures as is necessary under the circumstances to keep the secrets a secret. And I know that there's a whole bunch of nuances to that, particularly under EU law. So Rebecca, please chime in on that.
Rebecca Swindells:
Just picking up on your earlier point, I think one thing to mention is that when all of these businesses went into lockdown, I think actually a lot of them were almost caught a bit short in terms of what systems they were using, how secure their systems were. And I think so many have learned almost through trial and error that they need to get more secure systems in place in their business. As to your point Meredith on privacy, and you obviously, yes, you need to be very careful. There are very strict measures in place, a very strict legislation in terms of monitoring what employees are doing. So, that has to be considered on a country by country basis.
Dave Dalton:
So lots of moving parts beyond just protecting trade secrets, there are also obligations when it comes to how you're protecting them, particularly as it involves with interaction with employees. Okay, Rebecca, let's go here. What if despite the best efforts of a company, a breach occurs, what's the next move for a company if something goes wrong?
Rebecca Swindells:
I think the really key thing when a breach occurs is to move quickly to address it. The immediate concern should be to identify how the breach happens, so that you can try and contain the risk as much as you can, and prevent further disclosure of your information because obviously once a trade secret has been widely disclosed it risks losing its value completely, and just being worthless. So you've got to stem the flow of information, and you've got to do it quickly. And then depending on the nature of the breach, it may be necessary to call in forensic experts, such as IT specialists to investigate how the breach occurred, and to make sure that the right security measures are implemented to, again, prevent it happening again.
Rebecca Swindells:
So, for instance, it may be that the breach occurred due to the business having inadequate security systems in the first place, or picking up on Meredith's point about training and educating your workforce, it may be that the person who disclosed it didn't actually realize the value of the information, didn't realize it was a trade secret because they hadn't received the right training, or it may well be that it was clearly intentional disclosure with intent to then go on and misuse that information, in which case I think the business has to take immediate action to try and identify those that have been involved in the wrongdoing, and consider whether to take legal action against them. One of the reasons we're doing so other than to try and get back your confidential information and prevent further disclosure, is to send a message to the business that this sort of behavior will not be tolerated, and to deter other would be infringes. I think that deterrent message is very important.
Dave Dalton:
Oh, clearly, clearly. Well, if you could, can you talk about some of the specific legal remedies available in the UK and the EU to companies that can prove that their trade secrets have been violated?
Rebecca Swindells:
Yeah, sure. So there's a wide range of legal remedies available from the courts both in Europe and in the US, which I'm sure Meredith can touch on. In these sort of cases, as I just mentioned, moving quickly is really important. So one of the most useful remedies that you may want to get in a trade secrets infringement case is injunctive relief. And that can come in a variety of different forms. You can get a search and seizure order, which is basically forcing those who are suspected of wrongdoing to handover materials such as laptops, mobile phones, memory sticks, that may have your trade secrets information on them. You can apply at court for what's called a prohibitory injunction, which is aimed at preventing a breach from happening in the first place, but where you have identified a real threat, or a real risk to theft of your confidential information.
Rebecca Swindells:
And you can also obviously get what we call a final injunction to prevent any further disclosure, or misuse of your trade secrets. And you can get an order for delivery up, or destruction of any material which infringes your trade secrets. And then, of course, there's a whole financial side of remedies you can seek, financial remedies in the UK, but only after the court has decided that there has been a breach. Normally in the UK that is done by two separate trials, you have a trial on liability, and then you have a trial on quantum. And it's open to the claimant actually to either seek an award of damages, which is that you compensate them for the loss that they've suffered from the breach, or if it turns out that the defendants, the infringes have made a lot of money from their wrongdoing, then you can get an account of the profits that they have made from their trade secrets breach.
Dave Dalton:
All right. So there's relief clearly available, and there are a couple of avenues to pursue there. Meredith, how does this play out in the United States? What remedies are available here?
Meredith Wilkes:
There are a lot of similarities in the United States to those that Rebecca mentioned. There's an added nuance in the US which is that trade secret claims are the product of both state law and federal law. And sometimes there are strategic reasons not to bring your claim under the federal law. Sometimes there are strategic claims not to bring it under state law. And so the facts and circumstances of any particular issue will govern your strategy there, and at some level could impact the remedy that's available to you as a trade secret owner. Rebecca is spot on. Usually the first thing you want to do is stop the dissemination of the trade secret. You need that injunctive relief, and injunctive relief is available in the United States. And you have some severe burdens that you have to demonstrate to be able to get it. But that is the number one remedy that you want to see.
Meredith Wilkes:
The seizure order that Rebecca mentioned is a little bit different in the United States, and it's a remedy that's available under the Defense of Trade Secrets Act, the federal cause of action for trade secret misappropriation. There's only been a handful of claims involving seizure orders so far in the United States, it's relatively new legislation, but it's the heightened standard even above the heightened standard that you would seek an injunctive relief, because an injunction speaks to use of the trade secret. And so you're enjoined from using the trade secret. The seizure goes a step further, and it goes to the actual device, and it might be a weapon that employers will use in this remote working environment where they will go to the court and say, judge, it's not enough that we enjoin former employee from using our trade secret information. That's not enough. We have reason to believe that that's not going to be good enough.
Meredith Wilkes:
And then you will have to show the court what the trade secrets are, where they're stored, and how someone might get access to it, and then you can get that enhanced seizure order that says, give us the thumb drive, give us the remote device, give us the laptop computer. So there are those injunctive components. The same sort of financial remedies are available in the United States. We typically do not bifurcate, so it will be the same trial on liability as it is damages, and you can get the plaintiff's harm and the defendant's unjust enrichment, and there's all different ways that we measure that depending on how many people are in the market, and what the defendant may, or may not, have done with the trade secret. There is a possibility of royalty type damages and computations. There's the possibility of having to pay for future use of the trade secret, those sorts of things.
Meredith Wilkes:
And there is also the option of pursuing criminal action against trade secret misappropriators as well, the Economic Espionage Act. And that can land up to 10 years in prison and millions of dollars in penalties in that respect as well. So there's three different buckets available for relief in the US as well.
Dave Dalton:
Sure. Well, lots of avenues for a wronged party to pursue that's for certain. Let's wrap up this part of the discussion with this, and then we're going to move on and talk more generally about the women in IP initiative. But Rebecca, let's finish with this. If I'm an operator of a company whose well-being is very reliant on trade secrets, give me one key takeaway when it comes to remote work arrangements? I've got employees working off-site, what's the one thing you want that person to know to protect their trade secrets?
Rebecca Swindells:
Yeah, Dave, I think the key here is to be proactive and organized. That's two takeaways, but they're both as important as each other. And you need, I think as this discussion is really demonstrated, you need to have the right systems and procedures in place. First to identify what your business's trade secrets are, which is not always obvious. Secondly, to keep them secure and to record the steps that you've taken to do that. So you can show the court if you ever have to go to court. And thirdly, to monitor potential misuse. As we've been discussing in a remote working environment at the moment, it's even more important to engage with your workforce, and to educate them as Meredith touched on earlier. Remind them of their obligations, ensure they know what information is confidential, so that they follow the right procedures, because without those procedures in place, you really risk failing at the first fence. And you won't be able to get a claim off the ground if you are unfortunate enough to have a trade secrets breach.
Rebecca Swindells:
And I said before, but I think it's worth reiterating that given the very nature of trade secrets, and the fact that once they've been disclosed in another authorized way, they potentially lose their value and they cease to be trade secrets at all. You've got to focus on prevention rather than cure. You've got to invest in getting those checks and balances in place at the outset.
Dave Dalton:
Sure. An ounce of prevention. Right? Well said, well said. All right. Thank you both. Great discussion. Before we close, let's talk about the Women in IP initiative at Jones Day. Meredith, despite some unique challenges to say the least here in the first part of 2020, the initiative is moving on with programming plans for the balance of the year. Can you tell us what's coming up, and where people can go for information if they're interested?
Meredith Wilkes:
Oh, absolutely, Dave. Yeah, we definitely persevere, right?
Dave Dalton:
You have to.
Meredith Wilkes:
I'm really, really pleased to report that Women in IT is continuing to offer our CLE series and our next program is June 26th as a matter of fact. Our Jones Day Women in IT partners are going to collaborate with our clients and community leaders, and offer our annual leadership program solely by webinar this year, focusing on positive growth through the pandemic. We're going to talk about converting the stress of the pandemic into positive opportunities in a post-COVID world. We're going to do an update, I think a much needed and well received update on where we are with respect to COVID-19 therapy and vaccine development. And we're going to have a nice discussion about the all women US Supreme Court oral argument in the Booking.com case, and that's the case Dave, you and I have discussed before.
Meredith Wilkes:
So really looking forward to that. Program is June the 26th. It's all webinars. So you can register for that on the Jones Day website and under the insights tabs, or you can just send us an email to womeninip@jonesday.com. We'll get you registered for that. New offering this summer that we're doing. We have our summer associates with us in the US, none of them are physically present in any of our offices. And so we're doing some virtual programming in various regions throughout the US this summer for our summer associates, talking to them about our Women in IP program. And of course later this year we've got a couple of more CLE programs we're ready to roll with in September and in November, and hopefully if you'll have us Dave, we'll do some additional podcasts.
Dave Dalton:
Well, of course, we'll always have you guys. This is always great. And thanks so much. We will put appropriate links in the text of this podcast, Meredith, so people can find information about the Women in IP programming moving forward. So we will help all we can. We always helped you. All right, Rebecca, Meredith, thanks so much for being here today. Great information. Rebecca, hope you enjoyed your first program with us. Let's do this again soon. I hope. And Meredith-
Rebecca Swindells:
Thank you.
Dave Dalton:
... thanks as always to you.
Meredith Wilkes:
Thanks so much.
Dave Dalton:
All right.
Rebecca Swindells:
Thank you.
Dave Dalton:
Both take care. You can find contact information for Rebecca Swindells and Meredith Wilkes at jonesday.com. While you're there visit the firms insights page for publications, videos, more podcasts, blogs, and newsletters. Subscribe to Jones Day Talks on Apple podcast, and wherever else podcasts are found. As always we thank you for listening. I'm Dave Dalton. We'll talk to you next time.
Speaker 4:
Thank you for listening to Jones Day Talks. Comments heard on Jones Day Talks should not be construed as legal advice regarding any specific facts or circumstances. The opinions expressed on Jones Day Talks are those of lawyers appearing on the program and do not necessarily reflect those of the firm. For more information, please visit jonesday.com.
