business gold mine or liability landmine?
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August, 2011
Sponsored by:
Business Gold Mine or Liability Landmine?SOCIAL MEDIA
Sponsored by:2 Social Media Whitepaper | Advisen Ltd.
W H I T E P A P E R | August, 2011
Executive summary
Social networking is a ubiquitous part of life in the 21st century. Facebook, the 800 pound
gorilla of social media, now boasts nearly 700 million members worldwide, more than twice
the population of the United States.1 In March, Twitter announced it had added an average
of 460,000 new accounts per day for the prior month, and was averaging 200
million tweets per day.2
Companies across the world are recognizing the power of social media and
are rushing to create Facebook pages and amass followers on Twitter. Some
companies are using the enormous volume of personal information compiled
by popular social networking sites to customize and target marketing messages
to well-defined demographic segments. Many firms use social networking web-
sites to research job candidates and some to monitor employee activities.
Online social networking can be a powerful tool for organizations of all types,
but it also presents a bewildering and rapidly evolving web of liability expo-
sures. Potential sources of liability range from copyright infringement to invasion of privacy
to consumer fraud law violations.
It is clear that companies need social networking guidelines to minimize risk. However, many
loss control measures are difficult to implement, monitor and enforce. They may even cause
friction with employees and even undermine the business benefits of social networking.
Decisions as to how to manage exposures necessarily involve risk-versus-reward tradeoffs.
Insurance protection has increasingly become an essential part of an overall plan to manage
risk, with coverage for many social media exposures available through cyber liability policies.
Business Gold Mine or Liability Landmine?SOCIAL MEDIA
Online social network-
ing can be a powerful
tool for organizations
of all types, but it also
presents a bewildering
and rapidly evolving
web of liability
exposures.
3 Social Media Whitepaper | Advisen Ltd. Sponsored by:
social media business gold mine or liability landmineW H I T E P A P E R | August, 2011
Tapping into the Social Media Phenomenon
“It is time for companies to embrace, not fear, emerging media. There is no other way to
remain competitive,” concludes public relations firm Burson-Marsteller in a recent review of
corporate social media usage.3
Even those increasingly rare people who do not directly participate in online social network-
ing can hardly escape its influence. Social media has become a preferred way for entertainers
to develop rapport with their audiences and politicians to communicate with their support-
ers. Sara Palin’s tweets have become a regular part of the news cycle, and former Speaker
of the House Newt Gingrich – hardly the face of the Facebook generation – announced his
candidacy for the president of the United States on Twitter with a link to a YouTube video.
Revolutions are fomented via Twitter and breaking news is transmitted across the globe in
real time on Facebook. Some of the most powerful images of the Tohoku earthquake and
tsunami that were broadcast on television news programs were amateur videos taken from
Facebook pages.
Facebook, YouTube, Twitter, and LinkedIn are among the largest and best known social
networking websites, but hundreds of other sites serve smaller, generally more narrowly fo-
cused, audiences. Many social media sites permit members to construct a profile of personal
information and to create a list of other members with whom they share a connection. They
then can navigate their list of connections as well as the lists of others. Members often post
messages, or upload photographs, music or videos, to be shared either publically or within
their network of contacts.
Businesses of all types have discovered that social media can be effective for launching new
products, building brand loyalty, identifying prospects and communicating with customers. It
also can facilitate business-to-business activities. A recent survey of more than 3,300 mar-
keters by Social Media Examiner found that 90 percent of respondents consider social media
important to their business, with 88 percent saying that the principal benefit is generating
more business exposure.4 PR firm Burson-Marsteller found that nearly 80 percent of the 100
largest companies in the Fortune 500 list use Twitter, Facebook, YouTube or corporate blogs
to communicate with customers and other stakeholders.5
Many companies are content with establishing a presence on social networking websites,
such as creating a Twitter account or a page on Facebook. Others seek to leverage the
enormous troves of personal information about members compiled by social media website
Facebook, YouTube,
Twitter, and LinkedIn
are among the largest
and best known social
networking websites,
but hundreds of other
sites serve smaller,
generally more narrowly
focused, audiences
4 Social Media Whitepaper | Advisen Ltd. Sponsored by:
social media business gold mine or liability landmineW H I T E P A P E R | August, 2011
owners. Facebook, for example, offers advertisers the ability to direct messages to audiences
according to factors such as location, age and interests.
A common use of social media is to screen job applicants. A 2010 survey commissioned by
Microsoft found that 79 percent of recruiters and hiring managers in the US have reviewed
online information posted to social networking sites and blogs to screen job candidates.6
While still a popular way to screen applicants, the effectiveness of the practice is diminishing
over time as social media sites beef up user privacy options.
Some employers also monitor employee activities outside working hours through social me-
dia. Employers often attempt to control what employees say about the company on social
media sites. On occasion employers have been accused of monitoring other aspects of em-
ployees’ personal lives, and in some cases taking job-related actions as a result.
A growing number of companies employ aspects of social media on their own websites. While
the phrase “social media” may most readily bring to mind mammoth social networking web-
sites such as Facebook, MySpace, LinkedIn and Twitter, blogs and message boards also are
forms of social media. These can be powerful tools for interacting with customers and build-
ing online communities, but they also expose the company to the headaches of managing
sometimes inappropriate content posted to the site by visitors, and can create unexpected
liability exposures.
Liability Issues
The social media liability landscape is undergoing rapid evolution. In some cases, legal prin-
ciples from the brick and mortar world port easily into the digital world of social media. In
other cases, however, established legal principles and precedents are inadequate for the ul-
tra-fast, fluid, borderless, highly transparent and near ubiquitous social media environment.
Companies attempting to manage their social media exposures frequently are confronted
with the fact that social networking tends to be far more freewheeling and informal, with
fewer checks and balances, than traditional marketing and communication channels. The
opportunities for oversights, errors, and purely boneheaded behavior increase exponentially.
The speed at which images and words can be cut, pasted and redistributed by anonymous
sources magnifies the risk of multimillion dollar lawsuits.
The opportunities for
oversights, errors, and
purely boneheaded
behavior increase
exponentially.
5 Social Media Whitepaper | Advisen Ltd. Sponsored by:
social media business gold mine or liability landmineW H I T E P A P E R | August, 2011
The opportunities for stumbling into trouble seem almost limitless, but many of the most
significant exposures fall into the following categories:
» Media-related liability exposures such as copyright and trademark infringement
and defamation;
» Consumer fraud and deceptive business practices;
» Violation of data security and privacy laws;
» Violation of employment laws; and
» Security laws violations.
Media-related exposures. Publishing anything on the Internet opens a company to the
same exposures faced by professional media companies such as newspaper publishers and
broadcasters. These exposures include defamation, invasion of privacy, copyright infringe-
ment, false advertising and trade libel.
Defamation and its commercial cousin, trade libel (or commercial disparagement), have
emerged as hot issues in social media liability. Most of the litigation to date, however, has
involved individuals rather than businesses as defendants. In one well-publicized case, mu-
sician Courtney Love was sued by clothes designer Dawn Simorangkir for defamation, inva-
sion of privacy and infliction of emotional distress for “an extensive rant” on Twitter about
how she was billed for custom clothing. The suit was the first to raise the issue of whether
a public figure’s comments in social media should be held to the same libel laws that apply
to professional news organizations or should be granted the more liberal standards afforded
an op-ed piece or a letter to the editor. Love settled out of court for $430,000, so the issue
was never adjudicated.
Copyright infringement is rampant on social networking websites, and companies must take-
care that their representatives are not among the infringers. In an incident that received wide
news coverage, the Republican National Committee settled a lawsuit alleging that the orga-
nization used a segment of Jackson Browne’s song “Running on Empty” without permission
in a YouTube video promoting presidential candidate John McCain. Senator McCain also was
named in the suit, though he claims to have had no hand in producing the video and did not
even know of its existence until the suit was filed.
Businesses that employ elements of social media on their own websites, such as blogs and
message boards, are exposed to allegations of copyright infringement and defamation. Many
Copyright infringement
is rampant on social
networking websites,
and companies must
take care that their
representatives are not
among the infringers.
6 Social Media Whitepaper | Advisen Ltd. Sponsored by:
social media business gold mine or liability landmineW H I T E P A P E R | August, 2011
blogs, for example, quote from news articles. However, news organizations usually are op-
posed to even snippets of unlicensed stories appearing in blogs and other types of social
media, and many have become more aggressive about policing the blogosphere. Nearly one
thousand publishers now have joined The Associated Press’ News Licensing Group which
launches in July. The organization will track and police the use of content from member news
organizations.
Outside contributors to interactive blogs and message boards often post copyrighted mate-
rial, or may make defamatory statements. In most cases, website operators are shielded from
liability by The Digital Millennium Copyright Act (DMCA) and the Communications Decency
Act (CDA). Protections under the DMCA and the CDA, however, have limitations. In order
to qualify for protection under the DMCA, for example, mechanisms must be in place to
respond to a copyright owner’s request for removal of infringing content. The site owner also
must not receive financial benefits directly attributable to infringing activity.
In a small, but closely watched case, Rodale, Inc., publisher of Runner’s World magazine,
threatened to sue LetsRun.com, a website operated by twin brothers Robert and Weldon
Johnson, for a 900-word Runners’ World article posted by a participant on LetsRun.com’s
community message board. The Johnsons removed the Runner’s World content from Lets-
Run.com, but Rodale again threatened legal action for a link on the message board to the
same article which, according to Rodale’s attorney, was “stripped of all Rodale ads and navi-
gational information and aids.” According to the Johnsons’ reply, the link was to Rodale’s
own printer-friendly version of the article that had indeed been “stripped of all Rodale ads
and navigational information and aids” – by Rodale. Rodale eventually backed down.
Consumer fraud and deceptive business practices. Social media can be a powerful tool
for promoting a company’s products and services, but without proper precautions it can open
a company up to allegations of consumer fraud and deceptive business practices.
The FTC routinely monitors cyberspace for company employees and agents masquerading as
independent third parties who are attempting to influence consumers. The FTC now surveys
blogs, Facebook, Twitter, and other websites for violations of rules aimed at infusing greater
transparency into the online marketplace. McDonald’s is just one of many companies to run
afoul of FTC rules. In 2006 it was discovered that a pair of blogs allegedly run by McDonald’s
devotees who seemed obsessed with the company’s Monopoly game were in fact “flogs” (fake
blogs) created and operated by the fast food giant.
The FTC routinely
monitors cyberspace
for company em-
ployees and agents
masquerading as
independent third
parties who are
attempting to influ-
ence consumers
7 Social Media Whitepaper | Advisen Ltd. Sponsored by:
social media business gold mine or liability landmineW H I T E P A P E R | August, 2011
Not only might the FTC bring enforcement actions for bogus blogs and reviews, companies
may also be targeted in class-action lawsuits by consumers and subject to legal action by
state attorneys general for violation of state consumer fraud laws. In 2009, the New York
State Attorney General’s office charged Lifestyle Lift, a chain of cosmetic surgery centers,
with posting fake consumer reviews on the Internet. The company agreed to pay $300,000 in
penalties and costs. According to the AG’s office, Lifestyle Lift employees created accounts
on Internet message boards and posed as satisfied customers.
In the Lifestyle Lift case, the company was accused of directing employees to pose as satis-
fied customers. But even well-intentioned employees who are genuinely enthusiastic about
their employers’ products can cause problems. FTC guidelines indicate that employees who
choose to favorably comment on their employers’ products or services on social media may
subject their employers to liability, especially if misleading statements result in injury to
consumers. This exposure will be examined in greater detail in the next report in this series,
Social Media: Employers’ Liability for the Activities of their Employees.
Violation of privacy laws. The major social media websites, and Facebook in particular,
have been magnets for suits alleging violations of privacy laws. At issue are who owns the
vast amount of personal information posted on these sites, who is permitted access to it, and
how it can be used. Thus far, lawsuits challenging this type of commercial use of personal
information have been directed towards the social network sites themselves, but new theories
of liability may someday drag advertisers into this litigation as well.
Efforts to monitor and control negative statements about a company by employees can result
in allegations of privacy law violations. In one significant case, Pietrylo v. Hillstone Restau-
rant Group, an employer was found liable after a manager infiltrated an online group estab-
lished by employees to vent grievances about the company. The site’s creators were fired for
violation of company policy involving “professionalism and a positive attitude.” They sued
and won a jury verdict that was upheld on appeal. At issue was how the site was infiltrated: a
manager requested, and was given, an employee/member’s log-in ID and password. The em-
ployee later testified that she felt pressured to give the manager her log in information, and
that she felt she would have gotten into trouble had she refused to do so. A jury concluded
that the manager had not been authorized to enter the site and returned a verdict in favor of
the plaintiffs on two counts: violation of the federal Stored Communications Act and viola-
tion of the New Jersey Wire Tapping & Electronic Surveillance.
The major social
media websites, and
Facebook in par-
ticular, have been
magnets for suits
alleging violations
of privacy laws
8 Social Media Whitepaper | Advisen Ltd. Sponsored by:
social media business gold mine or liability landmineW H I T E P A P E R | August, 2011
Other state and federal laws that could trip up employers that are overly aggressive in moni-
toring or attempting to control employee communication through social media include the
Electronic Communications Privacy Act, the Computer Fraud and Abuse Act, various wiretap-
ping laws, and common law invasion of privacy theories.
Violation of employment laws. Social media offers employers unprecedented access to
the details about the personal lives of job applicants and employees, but it also creates
new opportunities to run afoul of state and federal laws intended to protect workers. For
example, in researching a job candidate, an employer may discover an applicant’s religion or
sexual preference, or find out that the applicant is pregnant or disabled. If the candidate is
rejected, the employer may be sued for discrimination. Even if the reason for rejection had
nothing to do with those attributes, often it is difficult to prove that discrimination was not
involved. Irrespective of outcome, the time and money required to deal with a lawsuit can
be considerable.
Employers are understandably concerned about statements made about a company by em-
ployees in social media. Many companies have social media policies that prohibit certain
types of comments about the company, its products, other employees and customers, as well
as the disclosure of sensitive information. However, recent cases have shown that companies
sometimes go too far in attempting to control employees’ communications and may violate
state or federal labor laws. In the first social media case to attract the attention of the Na-
tional Labor Relations Board (NLRB), a Connecticut-based ambulance company, American
Medical Response of Connecticut, allegedly fired an employee in violation of federal labor
law for criticizing her boss on Facebook. The criticism violated the company’s written social
media policy. According to the NLRB, because federal labor law allows employees to openly
discuss working conditions, wages and other work-related topics, and since she made the
Facebook comments on her own computer and during her personal time, the employee’s
words constituted protected speech. American Medical Response of Connecticut settled the
suit in April for an undisclosed amount and agreed to revise its social media policy.
More recently, the NLRB issued complaints against two employers for firing employees based
on their Facebook postings. In one case, the NLRB issued a complaint against a Chicago-
area car dealership that terminated a sales employee because of Facebook postings that
criticized the dealership. The salesperson complained about substandard food and drinks
served at a dealership event promoting a new BMW model. In the other case, five employees
of Hispanics United of Buffalo, a nonprofit that provides social services to low-income cli-
ents, engaged in a Facebook discussion that criticized the organization’s working conditions,
staffing and workload. All five employees were terminated, ostensibly because the postings
Many companies have
social media policies
that prohibit certain
types of comments
about the company,
its products, other
employees and cus-
tomers, as well as the
disclosure of sensitive
information
9 Social Media Whitepaper | Advisen Ltd. Sponsored by:
social media business gold mine or liability landmineW H I T E P A P E R | August, 2011
harassed an employee referenced in the initial posting. In both cases, the NLRB maintained
that the postings were protected concerted activity because employees were discussing con-
ditions of employment.
Securities laws violations. In 2008 the Securities and Exchange Commission (SEC) issued
an interpretive release concerning dissemination of information to investors through compa-
ny websites. The release also contains guidance on “interactive web sites,” a phrase which
the SEC used in the context of social media applications on a company’s own website such
as blogs and electronic shareholder forums. The SEC views these means of interaction with
stakeholders favorably, but warned that, “since all communications made by or on behalf of
a company are subject to the antifraud provisions of the federal securities laws, companies
should consider taking steps to put into place controls and procedures to monitor statements
made by or on behalf of the company on these types of electronic forums.”7
While the SEC did not address third-party social networking services like Facebook and Twit-
ter, clearly the same issues apply. In addition to potential run-ins with the SEC, companies
need to be concerned about private securities lawsuits alleging fraud as a result of erroneous
or misleading information disseminated through social media.
Companies also should take care that company blogs, message boards, etc., or messages
posted by company employees in other public forums, do not expose the company to charges
of market manipulation or false rumors. They should assure that all outlets for discussion and
dispersal of information are being properly and lawfully used.
Loss Prevention
A growing number of companies have social media policies, but often they are focused exclu-
sively on unofficial employee use of social networking websites. Employee social media poli-
cies are important, but they address only a limited range of liability exposures. Companies
increasingly use social media for marketing and for communicating with investors and other
stakeholders. Policies should encompass all aspects of a company’s involvement in social
media, including:
» Maintain control over the creation of social media channels. Burson-Marsteller
found that companies engaged on Twitter, Facebook and YouTube tended to have mul-
tiple accounts: each active company reviewed in their survey had 4.2 Twitter accounts,
2.1 Facebook pages, and 1.6 YouTube channels. The PR firm found that for companies
with multiple Twitter accounts, typically one was a primary corporate account while
Companies also
should take care that
company blogs, mes-
sage boards, etc., or
messages posted by
company employees in
other public forums,
do not expose the
company to charges of
market manipulation
or false rumors
10 Social Media Whitepaper | Advisen Ltd. Sponsored by:
social media business gold mine or liability landmineW H I T E P A P E R | August, 2011
other accounts often “were started and managed by a local market office, represented
a research or special-interest division at the company or was related to a corporate spon-
sorship event the company was engaged in.” Researchers often found it difficult to de-
termine which Twitter account was the primary corporate account — if there was one.8
Enterprising divisions or branch offices should be applauded for their initiatives to
grow business or advance other aspects of an organization’s agenda, but compa-
nies need to control the messages delivered to stakeholders. No company Twit-
ter accounts, Facebook pages, YouTube channels or other similar social media
accounts or memberships should be permitted without official approval and cen-
tralized company guidance. Additionally, each account should be clearly identi-
fied such that there is no confusion as to which is the primary corporate account.
Some organizations have what sports network ESPN calls “forward-facing talent,” –
analysts, reporters, columnists, etc. – who may have their own blogs, Twitter accounts
or Facebook pages. These forums may be clearly identified as belonging to the indi-
vidual, not the employer, but forward-facing talent often is perceived as representing
his or her employer despite strong disclaimers. As a result, some organizations treat
these blogs, etc., as if they were official outlets of the company, and limit what this
class of employee is allowed to discuss in these forums.
» Provide training to employees designated to represent the company through
social media channels. Companies should designate employees who are autho-
rized to represent the organization through social networking. Other employees should
be informed that they are not authorized to speak on behalf of the company. Au-
thorized company representatives should have training to assure they professionally
represent the company and that they avoid such things as defamation, trade libel,
copyright infringement, consumer fraud, and disclosure of non-public information.
Some employers may tolerate, or even encourage, business networking through so-
cial media such as LinkedIn. These forums can be powerful tools for cultivating a
network of sales prospects, communicating with clients, and staying abreast of the
latest developments within one’s business community. Companies should be aware
of – and have veto power over – all employees using LinkedIn or similar social media
for company-related purposes. Written social media guidelines are essential, and
training similar to that provided to employees contributing to official company social
networking outlets is advisable.
Some organizations
have what sports
network ESPN calls
“forward-facing
talent,” – analysts,
reporters, columnists,
etc. – who may have
their own blogs,
Twitter accounts or
Facebook pages
11 Social Media Whitepaper | Advisen Ltd. Sponsored by:
social media business gold mine or liability landmineW H I T E P A P E R | August, 2011
» Identify the types of information that require legal review before being re-
leased. Some companies require legal review of all communication with stakehold-
ers. However, that may not be practical or desirable for social media, where a greater
degree of personalization, spontaneity and timeliness are expected. Certain types of
information nonetheless will always require input from a lawyer before being released.
Examples include financial disclosures; discussions about competitors or their prod-
ucts; and information about the company’s own products, especially if making claims
about their safety, security or performance relative to other products.
» Develop procedures and standards for using social media to research job can-
didates. Employment law experts advise that posting and adhering to objective job
criteria is a first step in avoiding allegations of discrimination from rejected candidates.
It is far more defensible to reject a candidate who doesn’t have the requisite number
of years of experience, for example, than it is to reject one who fails the “good people
skills” criterion. Nonetheless, most hiring decisions are at least partially subjective,
and having knowledge of such things as candidates’ sexual orientation or disabilities,
which may come to light when reviewing social media activities, can lead to trouble.
The Catch-22 for employers is that it could be alleged they were negligent if they
failed to review all available information about a candidate, and something easily
discoverable becomes a factor in subsequent injury caused by the employee. Since it
is advisable that employers review social media for red flags, but problematic if they
discover in the process that the candidate belongs to a protected group, some em-
ployers are using third party services to conduct social media reviews. These services
produce a report that highlights both positive and negative attributes, but does not
include sensitive information that could be the basis of discrimination allegations.
» Incorporate social media into an enterprise risk management framework. So-
cial media can touch many parts of an organization and can result in financial, repu-
tational and regulatory risks. Areas involved with social media, or which should be
providing input into social media policies, include marketing, human resources, in-
vestor relations, corporate communications, risk management and the general coun-
sel’s office. Companies with enterprise risk management (ERM) frameworks in place
may be able to more easily accommodate the multidisciplinary, cross-departmental
requirements of managing social media exposures.
The Catch-22 for em-
ployers is that it could
be alleged they were
negligent if they failed
to review all available
information about a
candidate, and some-
thing easily discover-
able becomes a factor in
subsequent injury caused
by the employee
12 Social Media Whitepaper | Advisen Ltd. Sponsored by:
social media business gold mine or liability landmineW H I T E P A P E R | August, 2011
Insurance
Despite companies’ best efforts to manage their social media exposure, lawsuits can happen.
Insurance coverage is essential.
Coverage for some social media exposures may be available under traditional Commercial
General Liability policies, but most likely for limited circumstances. The insurance industry
has responded in recent years to social media and other online exposures by introducing
specialized cyber liability policies. In addition to coverage for some social media activities,
cyber liability policies cover other risks associated with doing business digitally such as data
security. Social media-related exposures typically covered by a cyber liability policy include
defamation, trade libel, invasion of privacy, copyright infringement, plagiarism, and infringe-
ment of title, slogan, trademark, trade name, trade dress, service mark or service name.
Cyber liability policies provide broad coverage, but they usually do not address the full range
of social media exposures. Insurance buyers should work with their brokers to assure their di-
rectors & officers liability (D&O) policies and employment practices liability insurance (EPLI)
policies will respond to social media claims brought by, as applicable, shareholders, competi-
tors, regulators and employees. Professionals offering advice throught blogs and other social
media channels should assure they have appropriate errors & omissions insurance.
Employee-related Exposures
This report addresses risks to companies for their own activities as concerns social media. Of
equal, or perhaps even greater, concern is the unsupervised activities of employees that can
have adverse effects on companies. Exposures include:
» Disclosure of privileged or confidential information;
» Defamation and trade libel;
» Harassment of other employees;
» Violation of consumer fraud laws; and
» Other activities that denigrate or embarrass the company, other employees, customers or
business partners.
Even if a company is not active in social media, it needs to be concerned about the social
networking activities of its employees. All companies should have social media policies and
have appropriate insurance coverage. The next report in this series, Social Media: Employ-
ers’ Liability for the Activities of their Employees, will look in detail at these exposures and
outline practical steps for managing the risks.
NOTES:1 “Audience Growth on Facebook: Top 25 Country Markets,” Inside Facebook, http://gold.insidenetwork.com/facebook/
2 “#numbers,” twitter blog, http://blog.twitter.com/2011/03/numbers.html
3 The Global Social Media Check-up: Insights from the Burson-Marsteller Evidence-Based Communications Group, Burson-Marsteller. p.2
4 Michael A. Stelzner, 2011 Social Media Marketing Industry Report: How Marketers are Using Social Media to Grow Their Businesses, Social Media Exam-iner, p. 5 (http://marketingwhitepapers.s3.amazonaws.com/SocialMediaMarketin-gReport2011.pdf)
5 The Global Social Media Check-up: Insights from the Burson-Marsteller Evidence-Based Communications Group, Burson-Marsteller. p.4
6 “Social Media Being Used to Screen Job Applicants,” Oh My Gov!, April 1, 2010 (http://ohmygov.com/blogs/general_news/archive/2010/04/01/social-media-being-used-to-discriminate-against-job-appli-cants.aspx)
7 SECURITIES AND EXCHANGE COMMIS-SION 17 CFR Parts 241 and 271 [Release Nos. 34-58288, IC-28351; File No. S7-23-08] COMMISSION GUIDANCE ON THE USE OF COMPANY WEB SITES p. 43
8 Burson-Marsteller p. 9
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