1. Social Media, Mobile Computing and The Cloud:
Why You Need a Current and
Comprehensive Compliance Program
Presentation to
Insurance Industry Charitable Foundation
November 9, 2011
Margaret A. Keane
415 951 1137
mkeane@dl.com
Dewey & LeBoeuf LLP
dl.com

2. TABLE OF CONTENTS
A. Issues Specific to the Insurance Sector
1. Use of Social Media by Farmers and some of its Competitors
2. Insurance Regulators and Social Media
3. The NAIC’s draft White Paper on Social Media in Insurance
4. From the States: Social Media as Advertising and Other Perils
5. Social Media as an Investigative Tool
6. Pointers, Perils and the FTC
B. Workplace Issues
1. Overview of Challenges
2. Hiring Concerns
3. Perils and Pitfalls of Mobile Technology
4. FINRA Guidance on Dual Use Devices
5. The NLRA, Non-disparagement Policies and Termination
6. Genetic Information Non-Discrimination Act
7. Parting Thoughts
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3. The Risks and Rewards
of Social Media Run Throughout Your Relationships
● Claims
● Community Relations
● Customers
● Employees
● Insurance Regulators
● Other Regulators and Enforcers
● Producers
● Underwriters
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4. Perils of Social Media and Mobile Computing
● Misappropriation of sensitive information due to negligent or
intentional security breach
● Reputational damage
● Harassment or bullying of co-workers in social media fora
● Inappropriate and/or defamatory references posted on public sites
● Claims of discriminatory hiring and firing decisions based on
information obtained from social media
● Violations of Genetic Information Non-Discriminatory Act (GINA)
● Wrongful termination claims for decisions and policies that may
violate the National Labor Relations Act
● Unfair insurance/trade practices exposure for inappropriate or
unauthorized endorsements and testimonials
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5. Farmers Insurance Group
• Offers Zynga’s FarmVille players access to its
Farmers-branded Airship, which raised fan base
by more than 100,000 in the first week of the
promotion.
• Ran a Facebook Contest where People could
Enter to Win a Ride on the Farmers Airship, the
Zeppelin Eureka.
• Incorporated Hearsay Social, a social media
platform designed to address compliance needs,
deliver content and provide data analytics; uses
the platform to help 15,000 agents nationwide
maintain their own Facebook pages.
• Launched iClaim which provides an additional
channel to submit claims and communicate with
Farmers.
• Manages active Facebook, LinkedIn and Twitter
Profiles.
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7. State Farm
● Launched a free mobile application, Driver
Feedback, which can turn a cell phone into a
pocket-sized driving coach.
● Held a 6-month ad campaign within the game
Car Town that included branded missions,
virtual item giveaways, and new State Farm-
branded promotions.
● Launched State Farm Go to Bat - Users select
one of the designated charities on State Farm’s
website, then virtually swing. Once a week, for
10 weeks, State Farm will make a donation of
$18,000 to the charity with the highest Go To
Bat game batting average. Also, an individual
winner who goes to bat for the winning charity
will be randomly selected for a trip to Games 3
and 4 of the 2011 World Series.
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8. Progressive
● Launched Snapshot, which plugs into a
car's on-board diagnostic port. Computer
chips collect and store the time of day the
car is operating, as well as speed. The data
are sent to Progressive via wireless
technology, and users can view their results
almost instantly on a website. Drivers can
get discounts of up to 30% in as soon as 30
days.
● Launched mobile application to compare
insurance costs; obtain quotes, make
payments and manage policies; access
insurance information, VINs, policy dates,
insurance coverages, and find nearest
agents and service centers.
● Progressive Flo, a character in
Progressive’s commercials, has a Facebook
Page with approximately 3,000,000 likes.
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9. Allstate
● Launched Digital Locker which makes it easy
to create and manage an inventory of
personal property, so customers will have the
information they need if they ever need to
make a claim.
● Launched Tag In by Allstate which allows
users to send quick messages and GPS
locations to friends.
● Launched Allstate Motor Club, which provides
roadside assistance for users nationwide.
● Launched GoodRide by Allstate – helps users
plan, track and share all rides, maintenance,
and repairs.
● Has its own YouTube channel which includes
a section of information and educational
videos.
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10. Regulators Are Stepping In
● State insurance regulators beginning to address the use of social
media in the insurance industry and treating it as advertising.
– Several state insurance regulators have Facebook pages.
– At least 3 states—Virginia, Massachusetts and New York—have
provided specific guidance that marketing communications through
social media platforms will be considered advertisements.
– At least 6 states—Ohio, New Hampshire, Idaho, Colorado, Arizona, and
California—and the NAIC include electronic communications,
broadcasting, or transmissions within their definitions of advertisement.
– NAIC has a Social Media Working Group, chaired by Keith Nyhan of
New Hampshire Department of Insurance. Draft Working Paper on
Social Media issued on July 29, 2011.
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14. NAIC Released Draft
White Paper on Use of Social Media in Insurance
● The Social Media Working Group’s White Paper, which borrows
heavily from FINRA’s Notice to Members 10-06, has not yet been
adopted by the Market Regulation & Consumer Affairs Committee.
However, it prescribes methods for insurers to comply with
regulatory guidance in their use of social media, and may
foreshadow future regulations.
● The White Paper focused on:
– The use of social media in the business of insurance
– Identifying and providing guidance on actual and potential regulatory
and compliance issues with the use of social media in insurance
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15. Context:
Common Uses of Social Media in the Insurance Sector
Insurers
● Tool to build trust and engagement and convey valuable information for
consumers.
● Means to obtain and verify information during the hiring process.
● Forensic tool to investigate potential fraud in the underwriting and claims process.
● Facilitate claims handling.
● Method of more timely addressing public relations crises.
Producers
● Ability to disseminate information. Can be product info or general public service.
● Tool to access networking opportunities.
● Means to engage customers and build personal brand, provide rapid responses to
questions.
Consumers
● Learn about products and rates, ask questions, rate insurance companies and
producers, and complain about negative experiences with companies/producers.
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16. NAIC White Paper:
When is an Insurer Responsible?
“Generally speaking, if the social
media communications can be
attributed to a carrier, regulators will
do so. Thus, protocols and
procedures should be developed, in
place, and followed regarding social
media usage by independent
agents, as the regulatory emphasis
in regards to social media will be on
the “agency” and not the
“independence”.
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17. White Paper:
When is an Insurer Responsible for Content?
● Insurers will likely be held accountable for social media content posted to or on any of
their own directly sponsored sites, and possibly for their producer’s social media
content.
● An insurer will likely be held accountable for all social media content, with limited
exceptions, posted to/on any of its associated entities’ sponsored sites/spaces
● Static communications are subject to existing advertising, marketing and customer-
relation regulatory frameworks. (Static communications remain posted and visible until
changed by someone with access to do so. Ex. Biographic materials, backgrounds and
wall information.)
● Retention and record keeping requirements do apply to the interactive content on a
social media website controlled by an insurer or one of its associated entities.
● Insurers are not responsible for the interactive content of 3rd party, non-associated
entities’ contributions
● If 3rd party content is attributable to an insurer because the insurer was involved with the
preparation of the content, the insurer will be accountable for the content, per the
“entanglement theory.”
● If 3rd party content is explicitly or implicitly endorsed by the insurer it becomes
attributable to the insurer per the “adoption theory.”
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18. White Paper:
The Many Facets of Compliance
● “As with all forms of communication and interaction between insurance
companies and their associated entities and consumers, the insurance
company must supervise and monitor communication closely in order to
comport with existing regulations.”
● Insurers should adopt comprehensive policies, procedures and controls that
comply with relevant State regulatory guidelines, including:
– Advertising and marketing laws and regulations
– Consumer complaints
– Endorsements of and to individuals and companies
– Privacy Laws – Federal laws including HIPPA, Gramm-Leach-Bliley
(“GLB”), Children’s On-Line Privacy Protection Act (“COPPA”), State
privacy laws such as California’s Insurance Information and Privacy
Protection Act (IIPPA)
– Record Retention Requirements
– Security Breach Notification Statutes
– Supervision, Monitoring and Training
– Suitability Requirements
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19. White Paper:
Regulatory Guidance
● Insurers should restrict producers from engaging in business
communications on unsupervised social media sites.
● Absent policies and procedures to ensure regulatory compliance, producers
should be prohibited from using social media to promote an insurer or its
products.
● Insurers should adopt policies reasonably designed to ensure that
electronic communications or communications attributed to them are
accurate and timely, not misleading.
● With regard to recommendations for specific insurance products, insurers
should ensure that its communications or communications attributable to it
are suitable to all potential recipients. Alternatively, an insurer could prohibit
interactive electronic recommendations for specific products.
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20. White Paper:
Regulatory Guidance (cont’d.)
● An insurer may employ risk-based principles to determine the extent to
which the review of its electronic social media communications is necessary
to properly supervise its business.
– Insurers could adopt procedures that require pre-approval of some or
all interactive electronic social media communications prior to posting.
– Insurers could alternatively review communications post-use.
● Insurers should have record retention policies and procedures for social
media communications, as well as appropriate privacy protections for social
media communications.
● Insurers should train their producers in accordance with their developed
policies and procedures to guide producers’ social media use (or risk
liability for their misuse).
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21. From the States:
Social Media Considered Advertisements/Marketing Material
● In Virginia, advertisement in the context of life insurance and annuities includes
websites and other Internet displays or communications, social media, or
other forms of electronic communications.
● In Massachusetts, marketing or marketing material in the context of health
benefit plans includes “Social media sites including networking sites, blog
postings and smartphone applications created by or for a Carrier, Insurance
Producer or other entity for presentation to or use by the insurance buying
public.”
● The use of a Linked-In profile page or a similar website for the promotion of
insurance, insurers, or insurance agents or brokers constitutes an
advertisement, announcement, or statement under New York Law. OGC
Opinion No. 10-11-07 (dated November 22, 2010).
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22. From the States:
Electronic Communications Considered Advertisements
● Ohio, New Hampshire, Idaho, Colorado mirror the NAIC Model Laws’ definition of
advertisement in the context of accident and health/sickness insurance - an
advertisement shall include printed and published material, . . . web sites and
other internet displays or communications, other forms of electronic
communications, billboards and similar displays. Ohio Admin. Code 390-8-07;
N.H. Code Admin. R. 2601.3; IDAPA 18.01.24 Section 010; 3 CCR 702 Reg. 4-2-3
Section 4.
● In California, in the workers compensation context, advertisements include any
form of communication, in writing, photograph or picture, electronic broadcasting
or transmission. Cal. Code Regs. tit. 8, Section 9820.
● Because insurers’ use of social media will be regulated akin to traditional
insurance marketing or advertising, social media communications must comply
with advertising and marketing laws and regulations, among others. Because
electronic advertising transcends state boundaries, insurers must be aware of
multi-state advertising laws.
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24. More Regulatory Pitfalls
● An insured may attempt to submit a claim or complaint
through an insurer’s Facebook page—insurers should
consider including a disclaimer regarding the proper
reporting of insured claims and a link to the insurer’s
claim form and/or other contact information.
● The use of social media is subject to state insurance
laws that govern unfair trade practices—insurers
should be aware of applicable laws and take great care
to follow their own privacy policies.
● As many states, including California, require that
marketing be conducted in the insurer’s name, if an
insurer is using a Twitter account, compliance
professionals should ensure that the account name
satisfies this requirement.
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25. Romano v. Steelcase:
Are Social Media Postings Discoverable in Personal Injury Cases?
● Injured woman sued furniture company for damages suffered when
she fell off a Steelcase chair
● Steelcase sought her Facebook and MySpace postings to show
that she had an active lifestyle and was not confined to bed as
alleged.
● Court concluded that she had no expectation of privacy as to her
Facebook and MySpace postings.
● “Thus, when Plaintiff created her Facebook and MySpace accounts,
she consented to the fact that her personal information would be
shared with others, notwithstanding her privacy settings. Indeed,
that is the very nature and purpose of these social networking
sites.”
● Same logic should apply in claims litigation, but case law is
evolving.
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26. Practice Pointers: Avoiding Regulatory Pitfalls
● Set clear expectations regarding online privacy when using corporate network
● Establish protocols for monitoring 3rd party posts and use disclosures that
adequately inform users.
● Set policies ensuring that insurers are appropriately identifying, monitoring,
responding to, tracking, and retaining records of complaints communicated
through social media.
● Ensure that personnel communication on behalf of the company is licensed
where necessary. Note that often, if an advertisement constitutes a solicitation
in a particular state then the advertising-insurer must be licensed in said state.
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27. Practice Pointers: Avoiding Regulatory Pitfalls (cont’d)
● Supervise producers and employees to ensure that
– only approved sites are being used;
– that any restrictions regarding use of approved sites are being followed;
– that static advertising is being pre-approved;
– and that only those permitted to use social media are using it; and
– use of social media in investigations is documented
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28. Geolocation Tracking and Telematics
● FTC: Geographic location is sensitive
information
● If a service provider links location to a
specific device of a specific person, provider
must:
– Give notice about how location information
will be used, disclosed and protected,
– State whether the provider will share location
information with third parties and identify
them,
– Advise users how they can terminate the
location-based services, and
– State how long information will be retained
Source: CTIA – The Wireless Association, Best Industry Practices and Guidelines for
providers of location based services
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29. The FTC Speaks:
Privacy by Design – FTC Proposal, December 2010
● Build privacy protections into everyday business practices:
– Provide reasonable security
– Collect only data needed for specific business purpose
– Retain data only as long as needed for that business purpose
– Safely dispose of data no longer needed
– Implement reasonable procedures to promote data accuracy
● Companies should implement and enforce procedurally sound
privacy practices throughout their organizations, including employee
training and conducting privacy review when developing new
products and services on a systemic basis
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30. The FTC Speaks:
FTC Testimonial Guidelines
● Governs endorsements and testimonials in advertising
● No private right of action; may be enforced by FTC under section 5
of the FTC Act
● Advertisers are subject to liability for false or unsubstantiated
statements made through endorsements
● Advertisers subject to liability for failing to disclose material
connections between themselves and endorsers
● Endorsements relating the experience of a customer must disclose
generally expected performance
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31. Social Media Issues In The Workplace
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32. Managing Change in the Workplace:
Some of Today’s Challenges
● Lack of clear precedent: courts and legislators lag behind while agencies
run ahead
● Social networking: lines between work and life continue to blur
● New communication channels: instant messaging as corporate tool and
texting is not just for teens
● Electronic discovery: the document that would not die
● Workplace privacy: does it exist?
● Anywhere, anytime access: security risk and other challenges of mobile
computing
● The 24/7 workplace and the FLSA
● Control is a remnant of days gone by
● Generational differences affect communication styles
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33. Social Media Policies 1.5
● 85% of financial services professionals under 50
are using social media. Ledermark survey, April
2010
● 45% of their employees don’t have a social media
policy or prohibit its use entirely. Ledermark
survey
● 31% completely prohibit employees from visiting
social networking sites while at work. Robert Half
Technology survey, May 2011
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34. Online Social Networks
● Facebook has over 700 million users
● Approximately 67 million users per day
access Facebook through Android and
iPhone apps.
● Linked in – 120 million plus members
● 110 million tweets are sent daily
● Don’t think your employees are out
there? Think again. Type your
company’s name into the search engine
of any social networking site.
(Source: thenextweb.com/facebook/ 2011/094/23/the-number-
growth-and-evolution-of-the-behemoth-that-is-facebook/)
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35. Getting to Know You:
Using Social Networking in the Hiring Process
● 24% of employers had hired a staff member based on their social
networking profile
● 33% decided not to make job offer to candidate after seeing profile
(photos of drugs/drinking or inappropriate behavior were the most
popular reasons for eliminating candidate)
● 16% of employees changed their web profiles to enhance their
professional images
● 22% of companies check candidates' profiles on
Facebook/MySpace before deciding to hire them (this has doubled
since 2006)
● 9% said they planned to review potential employees' social
networking pages in the future
Source: www.Careerbuilder.com/Article/(B-533)
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36. Getting to Know You:
Risks of Using Social Networking Websites in the Hiring Process
● Risk of making employment decisions based on
inaccurate, irrelevant or false info
● Online social networking profiles often present
personal information that would not properly be
subject to inquiry during the hiring process
● Potential to eliminate applicants based on
protected class status in violation of federal and
state anti-discrimination laws
● Need to balance applicant’s rights with employer’s
need to screen candidates thoroughly
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37. Getting to Know You:
Risks of Using Social Networking Websites in the Hiring Process
● Employers must have procedures for use of online data when
making employment decisions
– Determine when on-line searches will be used in hiring and promotion
process
– Decide whether to inform applicants about on-line searches and
whether to ask for email addresses, user names and blog post
– Comply with FCRA if using third parties to conduct search
– Do not engage in unauthorized access of password protected sites
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38. Are You at Work?
Mobile Technology Blurs the Line Between Home and Work
● By one estimate, 72% of Americans check their
email on weekends and vacations and 42% check
email while home sick.
Source: www.kikabink.com/news/most-workers-addicted-to-email-2-out-of-3-u-
s-and-u-k-workers-check-mail-outside-business-hours/ (citing Harris Interactive
research)
● iPass Mobile Employee Definition: Employee using
a mobile device who accesses networks (other than
corporate LAN or WLAN) for work purposes
● Average mobile worker works 240 hours per year
longer than work force in general
● 43% of mobile workers keep smart phone at arm’s reach when they sleep
● 96% of mobile workers under 45 have smart phones
● 35% of mobile workers check email first thing upon awakening
Source: The iPass Global Mobile Workforce Report, August 2011
www.mobile-workforce-project.ipass.com/cpwp/wp-
content/files_mf/ipass_mobileworkforcereport-q-3_2011.pdf
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39. Yours, Mine and Ours:
A New World of Sharing
How do you use your smartphone?
Source: The iPass Global Mobile Workforce Report, http://
mobile-workforce-project.ipass.com/cpwp/wp-
content/files_mf/ipass_mobileworkforcereport_q3_2011.pdf
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40. Yours, Mine and Ours:
A New World of Sharing (Cont’d)
Do you use your tablet primarily as a personal or work device?
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41. I Owe You What?!
Mobile Devices and Wage and Hour Obligations
● The average professional spends
50 minutes a day sending e-mails
after work
(Source: Cohesive Knowledge Solutions, 2008)
● Companies need to manage risk by:
– Updating policies and handbooks
related to use of personal devices
– Don’t give mobile devices to non-
exempt employees
– Implement policies that restrict non-
exempt workers use of company-
issued devices
FAD Media, Inc.
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43. Living Together:
The Ongoing Employment Relationship
● Decide whether or not to monitor - virtually all employers retain the right to
monitor and address personal use of the employer’s system
● Develop policy on use of personal devices in the workplace
● Put your policies on personal use and privacy rights into clear and unequivocal
language and communicate it to your employees
(Ex. You have no expectation of privacy in connection …)
● If employees can access the employer’s system remotely, require employees
to provide access to remote devices used to access system
● Require employees to provide immediate notice, and consent to remote wipe,
is a mobile device is lost
● FOLLOW YOUR POLICY CONSISTENTLY
● Revise policy as technology evolves
● Don’t make employment decisions turn on trivial matters
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44. FINRA’s Latest Guidance on Dual Use Devices:
Regulatory Notice 11:39, August 2011
● Recordkeeping
● Q1: Does determining whether a communication is subject to the
recordkeeping requirements of SEA Rule 17a-4(b)(4) depend on whether
an associated person uses a personal device or technology to make the
communication?
● A1: SEA Rule 17a-4(b)(4) requires a firm to retain records of
communications that relate to its "business as such."
This analysis does not depend upon the type of device or technology used
to transmit the communication, nor does it depend upon whether it is a firm-
issued or personal device of the individual; rather, the content of the
communication is determinative.
For instance, the requirement would apply if the electronic communication
was received or sent by an associated person through a third-party's
platform or system. A firm's policies and procedures must include training
and education of its associated persons regarding the differences between
business and non-business communications and the measures required to
ensure that any business communication made by associated persons is
retained, retrievable and supervised.
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45. FINRA’s Latest Guidance
Accessing Social Media Sites From Personal Devices
● Q14: May associated persons use personal communication devices and other
equipment, such as a smart phone or tablet computer, to access firm business
applications and perform business activity if the firm employs technology that
enables the firm to keep records and supervise the activity?
● A14: Yes. Firms may permit their associated persons to use any personal
communication device, whether it is owned by the associated person or the
firm, for business communications. Of course, the firm must be able to
retain, retrieve and supervise business communications regardless of
whether they are conducted from a device owned by the firm or by the
associated person.
. . . firms should have the ability to separate business and personal
communications, such as by requiring that the associated persons use a
separately identifiable [secure] application on the device for their business
communications. . . If the firm has the ability to separate business and
personal communications, and has adequate electronic communications
policies and procedures regarding usage, then the firm is not required to
supervise the personal emails made on these devices. Of course, firms
also are free to treat all communications made through the personal
communication device as business communications.
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46. Breaking Up is Hard to Do:
From Dooce to the NLRB
● Dooced: Termination based on a blog posting; see www.dooce.com
(blog of woman who was fired after writing about employer on blog)
● NLRB v. American Medical Response Company, Case No. 34-
CA-12576 (Connecticut, 2011). Employee terminated for criticizing
her supervisor on Facebook in violation of policies. Important case
because it challenged both the firing decision AND the employer’s
policies. Case recently settled.
● NLRB v. Hispanics United of Buffalo (“HUB”), September 2, 2011.
First ruling by an NLRB Administrative Law Judge, ruled that HUB
violated the NLRA when it terminated five employees for criticizing
a sixth co-worker on Facebook
“It is irrelevant to this case that the [Facebook posters] were not trying
to change their working conditions and that they did not communicate
their concerns to HUB”
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47. NLRB Position on Social Media Practices and Policies:
My Workforce Isn’t Unionized. Why Should I Care?
● Portions of the NLRA apply to ALL
private employees.
● Specifically, employers can’t punish
employees for discussing working
conditions or unionization.
● Agency has taken aggressive stance on
terminations as discipline for critical
posts on social media.
● NLRA gives employees the affirmative
right to engage in concerted action for
mutual benefit and protection.
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48. NLRB Acting General Counsel Releases Report
on Social Media Cases: August 18, 2011
● Report provides analysis of 14 cases
involving employer’s social and general
media policies submitted to NLRB’s Division
of Advice.
● Four cases found protected activity where
employees posting on Facebook were
discussing terms and conditions of
employment with fellow employees. Four
other cases found activity was not protected.
● In five cases, Division of Advice found that
some provisions of employers’ social media
policies were unlawfully over-broad.
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49. Breaking Up is Hard to Do:
Insurance is a Competitive Business
● Tell employees that their company issued
electronic devices will be “scrubbed” or
“wiped” in the event of termination and get
written acknowledgement.
● Draft non-solicit and non-competes that
provide that communications to clients on
social networking sites, including but not
limited to Facebook, LinkedIn and Twitter,
will be deemed a solicitation in breach of
covenants.
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50. Breaking Up is Hard to Do
Carol Bartz “Quits” Yahoo Board
On Thursday, Bartz said, in a sassy interview with
Fortune, that she was staying on as a director. “Ms.
Bartz is obligated to resign from the board and we
expect her to do so,” the board’s spokesman said after
the interview was published. She resigned the next
day.
After calling the board members “doofuses” who “f-ked
me over,” we have to imagine any future board
meetings would have gotten just a wee bit awkward.
www.mogulite.com
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51. Genetic Information Nondiscrimination Act of 2008 (GINA)
● Illegal to discriminate against employees or applicants because of genetic
information
● Employers may not use genetic information in making employment
decisions and may not request, require or purchase genetic information
● Any employer that possesses genetic information about an employee must
maintain such information in separate files; and must treat it as a
confidential medical record and may disclose it only under very limited
circumstances
● Prohibition on requesting information defines “request” to include
“conducting an internet search on an individual in a way that is likely to
result in a covered entity obtaining genetic information.” 29 C.F.R. §1635
● Safe harbor for inadvertent acquisition applies where employer
“inadvertently learns genetic information from a social media platform where
he or she was given permission to access by the creator of the profile at
issue (e.g., a supervisor and employee are connected on a social
networking site and the employee provides family medical history on his
page).” 29 C.F.R. §1634
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52. Guidelines for All
● Decide whether to permit/prohibit/limit or encourage blogging using
company resources or time
● Prohibit disclosure of trade secrets or confidential info and violation
of harassment policies
● Direct employees to use disclaimers
– “This post reflects my personal views, not those of the company”
● Be careful about threatening disciplinary action for disparaging
statements; consider NLRA implications
● Have employees execute current confidentiality agreements and
non-disclosure agreements
● Review non-competes to address use of LinkedIn and other social
media sites to evade non-compete and non-solicit obligations
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53. E-Discovery and Privacy
● Sensitive personal information is everywhere…
– Instant messages
– E-mails
– Text messages
– Online registrations
– Social networking
● All of these electronic records could be discoverable in litigation,
and could be monitored by an employer
● Privacy concerns are closely related to document management and
e-discovery
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54. QUESTIONS?
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55. Offices Worldwide
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