BloostonLaw Private Users Update Published by the Law Offices of Blooston, Mordkofsky, Dickens, Duffy & Prendergast, LLP [Portions reproduced here with the firm's permission.] www.bloostonlaw.com |
| Vol. 11, No. 9 | September 2010 |
 Court Says Cops Don’t Need Warrant To Obtain Certain Historic Cell Call Location Data Our clients using commercial wireless services for their internal communications now have a little less privacy. The 3rd U.S. Circuit Court of Appeals in Philadelphia has ruled that federal law enforcement agents do not always need to have “probable cause” and a warrant to obtain “historic cell tower data” associated with an individual’s cell phone calls. At issue in the case—In re Application of United States of America for Order Directing Provider of Electronic Communication Service to Disclose Records to Government—is whether the disclosure of Cell Site Location Information (CSLI) to law enforcement turns a cell phone into a “tracking device” under the federal wiretap laws. The Court specifically focused on the Stored Communications Act (SCA), which addresses the disclosure of electronic communications by service providers. Cell tower data is classified by the SCA (in Section 2703) as "records concerning electronic communication service or remote computing service." In this case, the government was seeking to monitor drug trafficking, and obtained a court order under the SCA. Its application sought access to “historical cellular tower data i.e. transactional records (including, without limitation, call initiation and termination to include sectors when available, call handoffs, call durations, registrations and connection records), to include cellular tower site information, maintained with respect to the cellular telephone number [of a subscriber or subscribers whose names are redacted].” As the 3rd Circuit noted, such a court order may be issued “only if the governmental entity offers specific and articulable facts showing that there are reasonable grounds to believe that the contents of a wire or electronic communication, or the records or other information sought, are relevant and material to an ongoing criminal investigation.” But the U.S. District Court for the Western District of Pennsylvania determined that disclosures of CSLI, like information from conventional tracking devices, always require a warrant and probable cause. The statutory definition of "electronic communication" specifically excludes information from tracking devices, and "tracking device" is broadly defined in a statute incorporated by reference into the SCA as "an electronic or mechanical device that permits the tracking of the movement of a person or object." The lower court concluded that a cell phone qualifies as a "tracking device" and that the government cannot obtain information from a "tracking device" under the SCA. The lower court also decided that “reasonable grounds" means "probable cause." The lower court's holding that probable cause was the correct standard appeared to be influenced by its belief that CSLI, and cell phone location information generally, make a cell phone act like a tracking device in that the CSLI discloses movement/location information. The 3rd Circuit, however, decided that the historic CSLI data requested in this case was not information from a "tracking device." The court took no position on whether a request for GPS data is appropriate under the SCA’s “less than probable cause” standard, and it observed that CSLI data provides only a rough estimate of a user’s location at the time a call is made or received. The court also agreed with the government that CSLI information, which is collected by cell towers, is a "wire communication" and, as such, falls within the scope of the SCA's authorization of the disclosure of information from providers of an "electronic communication service." In its ruling, the 3rd Circuit rejected the argument that Fourth Amendment case law requires probable cause for collection of historic location tracking information. It noted that the U.S. Supreme Court has held that the Fourth Amendment does not require probable cause and a warrant to follow a tracking device on a vehicle on the public roads but does require probable cause and a warrant to follow a tracking device placed on property that is taken into a home or other private location. The government had argued that no Fourth Amendment privacy interest was implicated because wireless carriers regularly generate and retain the records at issue, and because the records provide only a very general indication of a user’s whereabouts at certain times in the past. The 3rd Circuit said it is clear that the privacy interests at issue are confined to the interior of the home, and that there is no evidence in this record that historical CSLI, even when focused on cell phones that are equipped with GPS, extends to that realm. In remanding the case, the 3rd Circuit concluded that “[t]he government is not free from the warrant requirement merely because it is investigating criminal activity.” However, the court noted there was an inherent contradiction or underlying omission in the SCA, and that it was “stymied by the failure of Congress to make its intention clear.” A statute that mandates disclosure of CSLI without requiring the government to show probable cause may evoke protests from cell phone users concerned about their privacy, but “the considerations for and against such a requirement would be for Congress to balance,” the 3rd Circuit said. “A court is not the appropriate forum for such balancing, and we decline to take a step as to which Congress is silent.” We expect the debate will continue (possibly to the Supreme Court) until legislation is introduced to remedy or clarify the SCA. In the meantime, we caution clients to be careful in disclosing customer information. While the appeal court found that a warrant was not needed in the Pennsylvania case, this ruling applied to a limited disclosure of historic cell tower information only. BloostonLaw contacts: Hal Mordkofsky, John Prendergast, Cary Mitchell, and Bob Jackson. FCC Proposes to Apply Wireless Hearing Aid Compatibility Rules to For Profit Private Radio Licensees The FCC has issued a Further Notice of Proposed Rulemaking (FNPRM) seeking comment on revisions to its wireless hearing aid compatibility (HAC) rules. Among the proposed rule changes, the FCC is asking whether it should now apply its hearing aid compatibility requirements to Part 90 Private Mobile Radio licensees and others providing service to a “substantial portion of the public.” This could subject SMR and other for-profit radio operations to the strict HAC compliance requirements for the first time, potentially at significant expense. Clients that would be adversely affected by such development should contact about participating in the rulemaking proceeding. As discussed below, the FCC has recently fined several licensees $15,000 each for relatively minor HAC violations. The Commission is initiating this proceeding to ensure that consumers with hearing loss are able to access wireless communications services through a wide selection of devices without experiencing disabling interference or other technical obstacles. In this FNPRM, the Commission seeks comment on potential changes to its HAC rules in three respects. First, the Commission proposes to extend the scope of the rules beyond the current category of Commercial Mobile Radio Service (CMRS) to include handsets used to provide wireless voice communications over any type of network among members of the public or a substantial portion of the public. The Commission seeks comment on this proposal, on whether considerations of technological feasibility or marketability prevent application of its HAC requirements to any class of these handsets, and on what transition period is appropriate for applying the requirements to newly covered handsets. Second, the Commission seeks further comment on whether to extend its in-store testing requirement beyond retail stores owned or operated by service providers to some or all other retail outlets. Third, the Commission seeks comment on whether to extend to all circumstances the ability to meet HAC standards for radio frequency (RF) interference reduction for GSM operations in the 1900 MHz band through software that enables the user to reduce maximum power output by up to 2.5 decibels (dB). Comments in this WT Docket No. 07-250 proceeding are due October 25, and replies are due November 22. The FNPRM was released in conjunction with the FCC’s HAC Policy Statement and Second Report and Order (effective October 8). In these documents, the Commission affirms that its HAC rules must provide people who use hearing aids and cochlear implants with continuing access to the most advanced and innovative technologies as science and markets develop, while maximizing the conditions for innovation and investment. The Commission also clarifies that its HAC rules cover customer equipment that contains a built-in speaker and is designed to be typically held to the ear, adopts a streamlined procedure for amending its rules to incorporate an anticipated revision of the HAC technical standard that will make it generically applicable across frequency bands and interface modes, and extends its disclosure requirements to provide consumers with information about multi-band and multi-mode phones that operate in part over bands or modes for which technical standards have not been established. In order to ensure that people with hearing loss will have access to new and popular models, while continuing to protect the ability of small companies to compete and to foster innovation by new entrants, the Commission modified the de minimis exception in its existing rule so that companies that are not small entities will be required to offer at least one hearing aid-compatible model after a two-year initial period. In recognition of specific challenges that this rule change will impose for handsets operating over the legacy GSM air interface in the 1900 MHz band, the Commission permits companies that will no longer qualify for the de minimis exception to meet hearing aid compatibility requirements by installing software that enables customers to reduce the power output by a limited amount for such operations. The Commission also amends its rules requiring manufacturers to deploy hearing aid-compatible handsets so that they apply to handsets sold through all distribution channels, and not only through service providers. The FCC recently issued separate $15,000 Notices of Apparent Liability for Forfeiture (NALs) against three GSM-based Tier III CMRS carriers for failing to offer consumers the required minimum number or percentage of digital wireless handsets that meet or exceed the RF interference standards for hearing aid compatibility. We remind clients of the current HAC handset deployment requirements, and emphasize the need for service providers to maintain accurate monthly records of their HAC handset offerings. The next round of HAC reports for CMRS service providers (including carriers and resellers) will be due Monday, January 17, 2011, and with end-of-year holidays around the corner, we strongly recommend that carriers confirm now that they have at all times been offering the required number (or percentage) of hearing aid compatible handsets, and that their record keeping systems are in place. The FCC’s HAC rules increased the required number of compliant handsets starting last year, and will continue to require the addition of compliant handsets through next year. BloostonLaw contacts: Hal Mordkofsky, John Prendergast, Cary Mitchell, and Bob Jackson.
FCC Grants W.Va. Waivers For I/B Pool Frequencies The FCC has granted the West Virginia Department of Health and Human Resources/State Trauma Emergency Care System (WVDH) 16 applications, each including an identical request for rule waivers, to use various Industrial/Business (I/B) Pool frequencies in the UHF band for public safety communications. WVDH operates a state-wide microwave network and transmitter sites that provide support for the West Virginia Interoperable Radio Project (WVIRP), a state-wide interoperable radio network comprised of a UHF digital Project 25-compliant, trunked radio system. According to WVDH, there are approximately 7,332 radios operating on the system, from 530 different agencies, using 49 transmitter sites across the state with 25 additional sites that are in the planning and construction phase over the next 24 months. In addition, according to WVDH, “[s]ince implementation in 2003, approximately $56.8 million of Federal, State and local funding has been invested, with an additional $20.7 million to be invested over the next 12 – 24 months.” WVDH indicates that the goal of WVIRP is to “provide at least six channels at each site to ensure adequate capacity for its diverse and expanding base of public safety users.” According to WVDH, it initially sought to satisfy these capacity requirements through Public Safety Pool frequencies, but was informed by APCO Automated Frequency Coordination, Inc., that there are not enough Public Safety Pool channels available to meet WVDH’s additional capacity needs. Because there were insufficient Public Safety Pool channels, WVDH worked with PCIA - The Wireless Infrastructure Association (PCIA), an I/B Pool frequency coordinator, for unassigned UHF channels that could be used by the WVIRP at the specified sites in the relevant areas of West Virginia, subject to appropriate waivers from the Commission. WVDH indicates that it did not consider non-UHF frequencies because such frequencies would not satisfy the WVIRP system requirements. In this regard, WVDH asserts that there currently is an “extensive, imbedded base of UHF transmitter sites and UHF mobile/portable radios” used on the WVIRP that “would not work on 700/800 MHz channels or on VHF channels.” WVDH also argues that the “VHF band … consists of unpaired channels and therefore would not meet the trunking requirements of the WVIRP,” and that “[i]ntegrating 700/800 MHz into the WVIRP infrastructure would also be a huge technical and financial challenge as the propagation characteristics of 700/800 MHz would be a poor fit for West Virginia’s unique geography.” WVDH sought a waiver of Section 90.33 and such other Commission rules as may be necessary, pursuant to Section 1.925. In this regard, WVDH argue that a grant of its Waiver Request would “facilitate further deployment of a state-wide interoperable public safety radio network covering the unique terrain and remote communities of West Virginia.” WVDH also argue that “[a]pplication of the [I/B Pool channel eligibility restrictions] would also be inequitable, unduly burdensome, and contrary to the public interest as the frequencies in question are not currently assigned in the relevant areas of West Virginia.” Finally, WVDH argue that it had “no reasonable alternative as there are not enough Public Safety Pool channels in the UHF band to meet its requirements, and other frequency bands are not compatible with the WVIRP network or the geography of the area to be served.” The FCC said that based upon its internal spectrum usage analysis covering the geographic areas in issue, it concluded that authorizing WVDH’s use of the I/B Pool frequencies it requested would not result in an inadequate supply of spectrum for the I/B Pool community, or otherwise result in spectrum inefficiencies. The FCC also observed that PCIA, apparently finding no interference concerns for other users, has approved of WVDH’s proposed use of these frequencies. Further, the FCC noted that no objection has been made by any other I/B Pool frequency coordinator against WVDH’s proposed use of these frequencies. In addition, because WVDH will be subject to the same technical requirements that apply to all other users of these I/B Pool frequencies, the FCC said a grant of the Waiver Request should not result in any increased potential for interference to other users of these frequencies. BloostonLaw contacts: Hal Mordkofsky, John Prendergast, and Richard Rubino.
FCC Grants Montana Use Of Public Coast Channels For Network The FCC has conditionally granted the State of Montana’s two applications for authority to use two VHF Public Coast (VPC) channels as part of its statewide communication system. In conjunction with these applications, Montana sought waiver of the Commission’s rules, in order to operate mobile units in excess of the power limits and base stations in excess of the power and antenna height limits. Montana seeks to construct a private land mobile radio system, which will operate as part of a statewide communication system. In this regard, Montana seeks to license a base station with associated mobile units on certain VPC channels. FCC rules state that base stations shall not exceed 50 watts output power and mobile units shall not exceed 20 watts output power while operating on the VPC channels. The rules also limit the antenna height of base stations operating on the VCP channels to an antenna height above average terrain (HAAT) of 122 meters. Montana seeks to operate the mobile units associated with its proposed base stations at an output power of 40 watts. Consequently, Montana requires a waiver of the power limits in order to exceed the 20 watt limit specified by this rule for mobile units operating on the VPC channels. Montana states that a waiver of the power limits is necessary in order to allow the mobile units operating on the VPC channels to be compatible with the mobile units operating on other channels in the Montana state-wide system. Montana also seeks to operate its base station with an output power of 68 watts and an antenna height above average terrain (HAAT) of 579.5 meters. Consequently, Montana requires a waiver of the power and antenna height limits in order to exceed the 50 watt limit and 122 meters HAAT limit specified by this rule for base stations operating on the VPC channels. The FCC concluded that Montana’s proposed operation of a base station at greater than 50 watts with an antenna height greater than 122 meters and mobile units at greater than 20 watts will likely create no risk of harmful interference to incumbent operators. In this regard, the FCC said its analysis indicates that no site-based public coast or public safety incumbents operate on the requested VPC channels in the State of Montana. The FCC found Montana has demonstrated that grant of a waiver would be in the public interest. In this connection, the FCC agreed with Montana that grant of the waiver – conditioned on Montana’s commitment to resolve any harmful interference caused to incumbents as a result of its operation – will enable it “to establish a connected, trunked VHF public safety radio system, for reliable use and interoperability throughout Montana,” consistent with the public interest. BloostonLaw contacts: Hal Mordkofsky, John Prendergast, and Richard Rubino.
FCC Reinstates Filing Freeze Along U.S. – Canada Border The FCC’s Public Safety and Homeland Security Bureau has reinstated the freeze on the filing of new non-rebanding related 800 MHz applications along the U.S.-Canada border until the earlier of: (1) April 14, 2011, or (2) the date on which the Bureau determines that accepting non-rebanding applications in a specific NPSPAC region will have no negative impact on rebanding. This reinstatement of the freeze on non-rebanding applications is needed to preserve vacant channels for licensees retuning their systems according to the reconfigured band plan adopted by the Bureau for licensees operating along the U.S.-Canada border. The Bureau established a thirty-month transition timetable, beginning October 14, 2008, for Wave 4 800 MHz licensees in the U.S. - Canada border regions to complete band reconfiguration. During this transition, licensees operating in the U.S. - Canada border regions are required to engage in planning and to negotiate and enter into Frequency Relocation Agreements (FRAs) with Sprint Nextel Corp. to transition to the new band plan. Coincident with adoption of the thirty-month transition timetable, the Bureau froze acceptance of new 800 MHz applications during the planning and negotiation period. The purpose of this application freeze was to preserve the spectral landscape in the U.S.-Canada border region while the 800 MHz Transition Administrator (TA) determined replacement channels for relocating licensees. That freeze ended on July 1, 2009. As of this date, some relocating licensees in the U.S.-Canada border region have yet to conclude FRAs with Sprint, and most border region licensees have yet to complete their system re-tunes. Accordingly, to preserve currently vacant channels for use by these licensees and avoid potential licensing conflicts that could delay rebanding, the Bureau has determined that temporarily reinstating the freeze is in the public interest. The Bureau therefore is re-instituting the freeze on acceptance of non-rebanding applications for 800 MHz licenses in the NPSPAC Regions listed in the Appendix attached to this Public Notice. This freeze also applies to those stations located within seventy miles of the borders of the NPSPAC Regions listed in the Appendix. The freeze applies only to applications for new facilities or modification applications that involve a change of frequency or expand a station’s existing coverage area. Applications that have no effect on frequency or coverage (e.g., administrative updates, assignments/transfers, and renewal-only applications) are exempt from the freeze. The Bureau said it recognizes that the application freeze may prevent some licensees from expanding their current facilities or obtaining new licenses. Consequently, it will monitor the progress of rebanding along the U.S. - Canada border and will lift the freeze before April 14, 2011 in any NPSPAC region where sufficient rebanding progress has been made that the grant of non-rebanding applications would have no negative impact on the rebanding process. In addition, for good cause shown, licensees may seek Special Temporary Authorization (STA) to expand their facilities or add channels during the freeze, based on an appropriate showing of public interest need as described in the Bureau’s December 2006 STA Guidance Public Notice. BloostonLaw contacts: Hal Mordkofsky, John Prendergast, and Richard Rubino.
OET Provides Guidance For Becoming Accreditation Body of Test Laboratories On September 14, 2009 the Office of Engineering and Technology (OET) identified and requested comment on certain types of information that an applicant should provide to be considered as an accreditation body of test laboratories under the FCC’s rules. OET invited comment on (1) any information that would be useful in assessing the credentials and expertise of prospective laboratory accreditation bodies, and (2) suggestions for a streamlined set of procedures that would facilitate the recognition of future additional laboratory accreditation bodies. OET also requested comment on a request from ACLASS Accreditation Services (ACLASS), an ANSI-ASQ National Accreditation Board Company (ACLASS), to be recognized by the Commission as an accreditation body that performs accreditation of laboratories testing equipment for authorization under Parts 2, 15 and 18 of the Commission’s rules. Section 2.948 (d) of the Commission’s rules sets forth the requirements for accreditation bodies and for test laboratories, and specifies that any entity seeking recognition from the FCC as an accreditation body must obtain the approval of OET. An entity will gain OET recognition as an accreditation body based on the requirements for accreditation bodies established by the International Organization for Standardization (ISO) and International Electrotechnical Commission (IEC). In addition, for an applicant to function as an accreditation body for the FCC, it must be competent to assess a test laboratory’s compliance with applicable ISO/IEC standards for operating a testing laboratory and conducting tests, and of assessing the laboratory’s ability to perform testing in support of the applicable FCC technical regulations. OET said it is the responsibility of the accreditation body to review the qualifications of a test laboratory's test personnel, management systems, record keeping and reporting practices; to send recognized experts to observe testing at the laboratory; and to verify the testing laboratory’s competence to perform tests in accordance with Commission-related measurement procedures. OET said three parties filed comments on the type of information that applicants should provide to be considered as a recognized accreditation body of test laboratories: American Association for Laboratory Accreditation (A2LA); International Association for Radio, Telecommunications and Electromagnetics, Inc. (iNARTE); and ANSI-ASQ National Accreditation Board/ACLASS. All three parties generally agreed that the type of information identified by the Commission in the Public Notice would demonstrate an applicant’s credentials and expertise to be recognized as an accreditation body, and they made suggestions for clarifying some of the elements. Based on the comments filed in response to the September 14, 2009 Public Notice as well as its experience with the equipment authorization program and the test laboratory accreditation process, OET is providing guidance on the type of information that an applicant who desires to be recognized by the Commission as a laboratory accreditation body should provide in support of its application. An applicant must submit to the Chief of OET a letter requesting such recognition, and OET will make a determination of recognition based on the information provided in support of an application. OET said the following types of information would provide the “best evidence” of an applicant’s credentials and qualifications to perform accreditation of laboratories that test equipment to Commission requirements, consistent with the requirements of Section 2.948 (d) of the Commission’s rules for accreditation bodies and for test laboratories: - Successful completion of a ISO/IEC 17011 peer review, such as being a signatory to the International Laboratory Accreditation Cooperation (ILAC) Mutual Recognition Arrangement (MRA) or other equivalent laboratory accreditation agreement;
- Experience with the accreditation of electromagnetic compatibility (EMC), radio and telecom testing laboratories to ISO/IEC 17025. This can be demonstrated by having OET staff participate in a witness audit of the accreditation body performing an assessment of an EMC/Radio/Telecom testing laboratory; or
- By having OET staff review the report generated by the National Institute of Standards and Technology (NIST) laboratory accreditation evaluation program conducted to support the Asia Pacific Economic Cooperation (APEC) Mutual Recognition Arrangement (MRA) for Conformity Assessment of Telecommunications Equipment.
An applicant that offers other evidence has the burden of demonstrating that the information would enable OET to evaluate its experience with the accreditation of electromagnetic compatibility (EMC), radio and telecom testing laboratories to ISO/IEC 17025. Accreditation personnel/assessors with specific technical experience on the Commission equipment authorization rules and requirements; and Procedures and policies developed for the accreditation of testing laboratories for FCC equipment authorization programs. In order to ensure the continued integrity of the laboratory accreditation program, OET staff will periodically review the accreditation process and maintain close coordination with each of the organizations that it has recognized to perform accreditations. OET staff will pursue opportunities to observe peer review assessments under the ILAC MRA process and to observe and/or participate in the NIST witness assessments of these laboratory accreditation bodies. This will help ensure their continued acceptable performance and provide us with information to assess periodically their credentials and expertise to maintain their status as Commission-recognized laboratory accreditation bodies. BloostonLaw contacts: Hal Mordkofsky, John Prendergast, and Richard Rubino.
Railroads Seek Waivers Of Power Limit For Operations In 450-470 MHz Band The FCC seeks comment on the respective applications of Norfolk Southern Railway Company and Union Pacific Railroad Company requesting temporary waivers of the power limit for telemetry operations in the 450-470 MHz band. FCC rules limit telemetry operations in the 450-470 MHz band to two watts transmitter output power. The railway companies have filed a petition for rulemaking requesting that the maximum permissible power for end-of-train (EOT) devices, which operate on frequency pair 452/457.9375 MHz, to be increased. EOT devices transmit information regarding the brake pipe pressure on the rear car to the lead locomotive for display to the locomotive engineer. As a practical matter, the FCC said, they must be mounted on the coupling knuckle behind the last car in the train, but the path from the end of the train to the front of the train is always blocked by intervening train cars, and also can be adversely affected by variable terrain factors. In order to minimize the possibility of communications link failure for EOT devices (especially on longer trains), the Commission seeks comment on whether to amend its rules to allow EOT devices to operate with up to eight watts transmitter output power. The rulemaking proceeding remains pending. The railroad applicants seek temporary waivers of the power limit in Section 90.238(e) to permit them to operate EOT devices with eight watts output power, pending the resolution of the rulemaking proceeding. The FCC said it expects other railroads to file similar requests in the near future. Comments in this DA 10-1653 proceeding are due September 21, and replies are due October 1. BloostonLaw contacts: Hal Mordkofsky, John Prendergast, and Richard Rubino.
FCC Grants B/ILT Waiver For Use Of Certain 800 MHz Band Frequency Pairs The FCC has granted a waiver request to operate a Business/Industrial/Land Transportation (B/ILT) communications system using certain 806-821/851-866 MHz (800 MHz) band Public Safety Pool frequency pairs in the vicinity of Wildwood, Missouri, filed by Ameren Services Company (Ameren). Ameren is a utility company that provides electricity to approximately 100,000 customers in the area to be served by the requested site. It states that there are no B/ILT channels available in the proposed service area, and that it needs the frequencies for dispatch communications with field crews that maintain and restore electrical service in that area. Ameren requests frequency pairs 854/809.9625 MHz, 858/813.9625 MHz, and 859/814.9625 MHz “because they have been historically assigned to Ford Motor Company in the Saint Louis metropolitan area … prior to the license being terminated on May 5, 2009, [and] thus the approval of this request will not impact Public Safety operations in the area.” Ameren, which already operates on other 800 MHz band frequencies in the area, needs a waiver of the Commission’s Rules because the requested frequencies are designated for Public Safety use. In support of its waiver request, Ameren submitted a letter from the Association of Public-Safety Officials-International, Inc. (APCO), one of the frequency coordinators for the 800 MHz Public Safety Pool, approving Ameren’s proposed use of the frequencies. No party opposed Ameren’s request in response to a public notice seeking comments on the request. The FCC concluded that the requested frequencies were licensed for B/ILT use until recently, and likely were not part of any planned Public Safety operations. In addition, given APCO’s concurrence and the Commission’s actions in the 800 MHz rebanding proceeding making additional 800 MHz band spectrum available for Public Safety use will not materially diminish the inventory of 800 MHz Public Safety spectrum in the area. BloostonLaw contacts: Hal Mordkofsky, John Prendergast, and Richard Rubino. This newsletter is not intended to provide legal advice. Those interested in more information should contact the firm. | 
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