JONES DAY TALKS®: Women in IP – 2020 in Review and a Look Toward 2021

Jones Day’s Meredith Wilkes and Anna Raimer discuss 2020’s most significant developments in trademark law and preview what’s to come in 2021, including possible progress in Washington on the highly anticipated Trademark Modernization Act.

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Dave Dalton:

It's very obvious we're fortunate here at Jones Day to get regular updates on intellectual property law from a number of our lawyers here. One of our most consistently popular programs and one I look forward to every year is the December Women in IP podcast, where we take a look back at the year's most significant developments in IP law and also talk about what to expect in the year ahead. We have Meredith Wilkes and Anna Raimer here to tell us what we need to know. I'm Dave Dalton. You're listening to Jones Day Talks. Meredith Wilkes co-leads Jones Day's global trademarks, unfair competition and copyrights group. She is a lead trial lawyer that has focused on high stakes trademark, trade dress, trade secret, false advertising and design patent litigation matters for global brands and federal and state courts throughout the US for more than 20 years. Meredith also chairs Jones Day's Women in IP initiative.

Dave Dalton:

And Anna Raimer has significant experience managing international brands for clients. She counsels clients regarding the development and protection of intellectual property assets in a wide range of industries and oversees all aspects of trademark clearance, prosecution, and maintenance, and she advises on trademark and copyright issues and license agreements and commercial transactions. Meredith, Anna, thanks for being here today.

Meredith Wilkes:

Thanks for having us, Dave.

Anna Raimer:

Thanks, Dave.

Dave Dalton:

Here we are. 2020 was not like any of us expected or envisioned, I'm sure. In fact, Meredith, you and I do this every year, every December, we do a look back and a look forward. Maybe I don't remember correctly, but nobody had predicted a global pandemic that would throw us all off for 2020. So under some strange circumstances. We got through the year, but I thought if you didn't mind talking about that for a minute, what was it like? And I always say practicing law is challenging enough with all the responsibilities and the plates you have spinning and so forth. You're trying to serve your clients. I assume business development is always a priority. You're helping younger partners and associates get acclimated. You've got pro bono responsibilities. Meredith, how'd you do it this year? This had to be probably one of the more difficult years of your professional career.

Meredith Wilkes:

Dave, it's funny, you talk about 2020, and I saw a meme the other day that said 2020 is no, no on its side.

Dave Dalton:

Right. That's good. That's good.

Meredith Wilkes:

And you're spot on. We do this every year. And you love to ask our group to look into the crystal ball and predict things that are going to happen down the pike. And I don't think anybody predicted where we would be right now. And it's certainly been full of a lot of different challenges to be sure. I can only imagine how difficult it would be for a new lawyer starting their practice and trying to learn how to be a lawyer and become part of the firm. I feel very blessed that I've got really great people who I work with and just great teams and a lot of resources that we have at a firm level and on a personal level.

Meredith Wilkes:

So there have been some challenges to be sure, but it's been great because we've got good technology and we've been able to really stay connected when in some ways I think, yes, we miss the personal connection to be sure but with all the WebEx calling and the Zoom calling and things like that, in some ways we're actually more connected I think as we see each other face-to-face on video calls than we've been in the past. To be sure, challenges, but also some great things have come out of it as well. And so it'll be interesting to see what happens in 2021.

Dave Dalton:

Yeah. I found what I miss and you mentioned the informal interaction, that's what I miss most. You pass somebody in the hallway. It's like, oh, I've been meaning to ask you about that. Or someone will pop by and just sit in your office and you catch up on an idea or you brainstorm something and you can still do that, but it's got to be orchestrated. It's got to be planned. Some of the spontaneity, I think helps, especially with what we do here in this department, but quite the year. Anna, I'm guessing 2020 was probably not your favorite year either. Tell me if I'm wrong.

Anna Raimer:

I'd agree with that, Dave. Lots of interesting challenges for 2020 learning how to practice law in a different way. Also added elementary school teacher to my resume since we had a lot of homeschooling in our household. So that was fun. Taught an internet law class all via Zoom. So had to learn how to do that. So just interesting things like you mentioned, didn't expect for 2020, so lots of fun surprises there.

Dave Dalton:

For sure. For sure. Well, things have to get better. So, fingers crossed. So let's talk about 2020. Even under these bizarre, unusual circumstances, it was still an eventful year for trademark law, at least in the United States. The Supreme Court heard three cases relating to the Lanham Act. Let's start with the United States Patent and Trademark Office v. Booking.com. Meredith, if you can, summarize the case and tell us what that decision ultimately means.

Meredith Wilkes:

Oh, you bet, Dave, and you've heard me say this before, and I'll say it again. I'm a self-professed trademark law nerd. So one of the super cool things I think about 2020 was the fact that we got to hear some of the oral argument in front of the United States Supreme Court, because they were streaming it. Ordinarily you have to go stand in line and be in Washington DC to actually get into the Supreme Court and watch the oral argument take place. And one of the super cool things about the Booking.com case was that it was the first streamed oral argument in front of the United States Supreme Court. So we could dial in and listen to the oral argument. So that was really awesome. Since we're doing a Women in IP podcast, the other added super cool thing was that you had all the litigants represented by women. Two women giving oral argument in front of the United States Supreme Court, which is super, super rare.

Meredith Wilkes:

So that was a really cool thing too, and both super talented litigators and really just so awesome to hear their interaction with the court. But from the Lanham Act standpoint, the question was whether or not the addition of a top level domain .com to an otherwise generic term booking, could then create a protectable trademark. Is the whole greater than the sum of its parts? And the United States Supreme Court ended up holding that yes, booking.com was in fact capable of protection and the adding that .com made it a protectable identifier.

Dave Dalton:

I remember you and I talking about this case, and I don't recall for certain what your take was. Were you surprised at the ruling or did it come out pretty much the way you expected?

Meredith Wilkes:

I was not surprised at the ruling and not because I'm some Lanham Act genius or predictor or that my crystal ball was working particularly well on any given day, but the way you cast the issue as a litigant can become very, very important in terms of how the court rules. And this is an excellent example of that philosophy in that you had essentially the United States Patent and Trademark Office asking for a categorical rule, a categorical prohibition against adding .com and creating an otherwise protectable mark. And any time you're asking for super huge steps like that, odds are, not always, but it makes it very difficult at that point to get the relief you're seeking. And so, because the Patent and Trademark Office was seeking a categorical prohibition, I was thinking that perhaps the Supreme Court was going to go the way of booking.com and say that it was a protectable mark and decline the invitation from the solicitor to make a categorical rule prohibiting it.

Dave Dalton:

I see. Booking, that's an action. It's a verb. If I wanted to try to trademark shopping.com, is that fair game now?

Meredith Wilkes:

It might be. It might be.

Dave Dalton:

I'm going to do it. I got to end this call because I'm going to go do that right now. All right. Let's move on.

Meredith Wilkes:

So it's a good point that you raise Dave, because one of the things that Chief Justice John Roberts talked about during the oral argument was exactly what you said with the shopping.com. And here's the key distinction. The reason that booking.com was okay is because the Chief Justice said no one refers to online sites where you would book travel as Travelocitys or Price Lines, and so that's the distinction here. It's a great point that you raise.

Dave Dalton:

Okay. Good enough. Well let's keep moving there. Two more Supreme Court cases we need to talk about, I think, and we'll stay with you Meredith on this one. Romag Fasteners, Inc. v. Fossil, Inc. This was about willful infringement, right?

Meredith Wilkes:

It was, and this ended a battle and a split, really a 50, 50 split in the circuits as to whether or not a successful plaintiff under the Lanham Act could recover profits without showing willful infringement. And so there had been a debate and a split as to whether or not you had to show willfulness to get profits as a measure of recovery. There was nothing in the Lanham Act that specifically required that you show willfulness to get profits. In fact, it just says that you can recover defendant's profits, but because it was seen as a disgorgement as some equitable remedy, some of the courts had fashioned relief over time that had said well, you have to show some element of evil intent or some willfulness before you're going to be able to get that relief. And after years and years and years and battles all over the place, the Supreme Court finally settled that score and said nope, it doesn't appear anywhere in the plain language. So it's not going to be an absolute requirement. It's a factor to be considered. And so that's where we've left it.

Dave Dalton:

I'm trying to remember, because we talked about this case also. There were conflicting rulings, different circuit courts, weren't there, or am I thinking of something else?

Meredith Wilkes:

No. You're spot on, there was a dead split among the circuits. So depending on where you were litigating the case could dictate what type of damages as a defendant you were looking at, or a plaintiff, what you may recover. And so you can imagine how that might lead to form shopping and other sorts of things, but where you were located, where your case was being tried, could really have an impact on the outcome.

Dave Dalton:

Well, the Supreme Court doing their job, bringing us some much needed clarity. That's for sure. Okay. Last one, Meredith. Lucky Brand Dungarees, Inc v. Marcel Fashions Group, Inc. This is interesting. You were kind enough as you usually do. You sent over some notes for me, but I sensed something underwhelmed you about this ruling, the case, the whole matter. And I don't mean to overstate that, but what's your take now and first of all, what happened and why your reaction vanilla, I guess, what's going on here?

Meredith Wilkes:

Okay.

Dave Dalton:

This is what we call leading the witness, isn't it?

Meredith Wilkes:

I think so. And compound, but all right. Let me unwrap that one a little bit.

Dave Dalton:

Okay, sorry.

Meredith Wilkes:

There are some people, I think who looked at this case and said how did this get to the Supreme Court in the first instance, and the reason I say that is because usually when a case in our space, in the Lanham Act space, usually when a case gets to the Supreme Court, it's a Romag type of case. It's a case where you've got a split among the circuits on an important issue. And we need somebody, the Supreme Court to come in and weigh in on what the law is and resolve the split among the circuits. That's usually how the Supreme Court weighs in on something like this. And here, the Lucky case really involved only the decision of the United States Court of Appeals for the second circuit. And so it was a little bit surprising in some respects that the court would take an issue that only was coming really out of a decision from one circuit.

Meredith Wilkes:

So that was one thing that made it at least sort of interesting to people watching from the sidelines in terms of why they would take it. The second is what the real issue was. And the question was whether or not this idea of defensive preclusion could apply, meaning that if you didn't raise a defense in an earlier case, would you be precluded from raising it in a future case? And the reason people were scratching their head and saying well, why is this, this major issue for the Supreme Court to be deciding, is, it would be so rare that the issue could ever come up. So what do I mean by that? This defensive preclusion thing became an issue because the parties had been litigating with each other for 20 years.

Dave Dalton:

Geez. It's like the Hatfields and the McCoys. Nobody remembers why this all started anymore.

Meredith Wilkes:

Sort of, yeah, just started with a fight between these two parties in 2001, and then they settled it and then they had another fight and a settlement was reached and then they had another fight and they tried to raise the issue that no, you released these claims. And so you can't sue us because you released them. And then they said no, you can't raise that because you should have raised it and you didn't raise it. And so that's how the issue percolated and got to the Supreme Court. It's really, it was a civil procedure issue more than a trademark issue. It just arose in the context of a trademark infringement case. That's how we got there. And then the Supreme Court held that there was no such thing as defensive preclusion. And so you're not forced to raise it or lose it if you were to be involved in serial litigation with another party.

Dave Dalton:

I know people switch law firms and so forth. If some of the original attorneys starting in that case, that's half someone's career, 20 years. I'm not saying that's all they worked on, but that's astounding to think about that. Talk about files and paperwork and reams of stuff. Good grief. 20 years. And that's probably not even a record, right?

Meredith Wilkes:

They do sometimes take on a life of their own, literally.

Dave Dalton:

Evidently. So, well, let's swing over to Anna for a second. Hey, by the way, Anna, I was going through some of my notes from some our previous podcasts. You were involved with Meredith in that famous Blurred Lines podcast. Remember that? A couple years ago.

Anna Raimer:

Oh yes, that was a fun one.

Dave Dalton:

That was the dust up, for people who don't remember, that was the dust up between the Marvin Gaye estate and Robin Thicke over, I don't remember the exact music terms or whatever, but basically, they thought Robin Thicke had ripped off part of Marvin Gaye's What's Going On for that Robin Thicke song that sold. Anyway, so you were around for that. Another time, I think we're doing a Supreme Court roundup cases or something, that might've been in '19. Anyway, so welcome back, Anna.

Anna Raimer:

Thanks for having me today.

Dave Dalton:

I can only guess that your third podcast is just as exciting as the first two. Isn't it, right?

Anna Raimer:

Has been fun so far.

Dave Dalton:

There you go. There you go. All right. The US Patent and Trademark Office, USPTO, made some rule modifications this year that we ought to examine. Tell us about the changes that came about during 2020.

Anna Raimer:

That's right, Dave. So effective February this year, the USPTO moved to mandatory electronic filing. Not a big deal because most people were already filing that way anyway, but for most types of trademark applications, as well as all the submissions that go along with the applications and registrations like your office action responses and your renewals, all of that needs to be filed electronically now. So that was the first big thing from the rule changes. The second was that the PTO now requires an email address for both the applicant or registrant and the authorized attorney if there is one. So before you could just have the authorized attorney's email address. Now you need to have the trademark owner too, even if they're represented by an attorney. Of course, there was a pushback on that issue, having that in the database. So now it's masked. You can't see it, but you do still have to provide it.

Anna Raimer:

The PTO wanted a way to contact the trademark owner electronically if for some reason the attorney's email couldn't be used, like the representation had ended. And the last thing to mention is that there were some updates to the requirements for trademark specimens of use. Most of these were just to conform with what was already existing requirements or precedential case law. But one to mention that I think is particularly of note, is that you need to make sure that the web pages that you use for specimens of use, so when you print out those website screenshots, that they have both the URL and the access or print date, because they need to have that to be accepted as specimens now.

Dave Dalton:

I see. These seem like reasonable changes, modern introducing tech and addressing the reality of maybe where things were going anyway, but people you're working with, clients and so forth, they're happy with this, indifferent, or did it make a big difference to them one way or the other?

Anna Raimer:

Not huge changes here. Most of this, we were doing already. We were already doing this with the specimens and filing electronically. We do now have to provide that email address, but that's not really a big deal for most clients. And I think it really is helping the trademark office, which was the purpose of the rule change, to really have some more administrative efficiency and optimizing their workflow processes to get rid of all that paper.

Dave Dalton:

There you go. Almost always a good thing. Okay, good. Let's talk about trade dress. And Meredith, I've got to be honest. You and I have been doing these for three years or something. I'm not sure we specifically ever talked about a trade dress matter. If we have, I forgot. And I apologize, but for people who maybe their knowledge is not complete on this, or they're not certain, before we get into the specifics of the Forney Industry case, tell us what trade dress matters address. What's that all about?

Meredith Wilkes:

Dave, you're right. I don't think we have ever talked about a trade dress case so trade dress is a form of intellectual property that's also protected by the Lanham Act. And it generally encompasses the visual appearance of a product or its packaging. So it's the packaging or the appearance. And it also has to indicate source. So in that respect, it's the dressed up look of something and it tells you who makes it. So what does it mean? We're talking about color, the Robin egg blue of Tiffany. Shape, the Coca Cola bottle or Fiji water bottle. Those are examples of trade dress. So that's what we're talking about. It can be protected by the Lanham Act, but it has a heightened requirement for protection. You have to show usually that it has acquired what's called secondary meaning, meaning that people when they see it associate it with a source. That's what we're talking about when we talk about trade dress.

Dave Dalton:

Okay. Good enough. So what happened with Forney Industries? What are the specifics of that matter? What happened?

Meredith Wilkes:

So this was an interesting case decided by the federal circuit, because historically people like Anna and me would tell clients if you're trying to protect color in the United States Patent and Trademark Office or through litigation, it's not inherently distinctive, meaning you have to show secondary meaning, the connection between the product and the source that I was telling you about a minute ago. And typically we would do that through surveys, which are time-consuming and very expensive. But the Forney decision from the federal circuit changed that. In Forney, we were talking about this multicolor mark on packaging for welding accessories of all things. When you think about color, you're thinking consumer goods, Tiffany, that sort of thing, but no, it was this multicolored packaging on welding accessories. And Forney sought to register this gradient yellow, red type of color on their packaging in the trademark office.

Meredith Wilkes:

And they did not submit that survey and it was refused and they took it all the way up. And the court held that multicolor packaging can be inherently distinctive. You don't have to show secondary meaning to get that multicolor trade dress registration. And so that one surprised a lot of people, because there are a lot of Supreme Court cases, historically the Qualtech's decision, the Walmart decision that say that color is not inherently distinctive and you have to show secondary meaning. So that one was a surprise. Don't know what's going to happen with that one, but race to the trademark office right now with your multicolor marks to try and get those registered in view of the federal circuit's decision.

Dave Dalton:

I guess so. And I'm not in product branding or brand management or everything, but as you were talking, I'm thinking of okay, the tide box. I saw my wife do laundry last night. That's why it was stuck in my head. But those very distinctive, those circles, orange and yellow and wherever those colors are. Could that be subject to trade dress protection if Procter & Gamble wanted to run out and say hey, we want to do this. Hypothetically. I don't know if Proctor & Gamble is doing that, but is that the kind of thing that might be protected now?

Meredith Wilkes:

Theoretically. Color, whether it's the Robin egg blue Tiffany or the brown on a UPS truck or the orange on a Tide box, or any individual color for sure is capable of trade dress protection, as long as it meets the statutory requirements. And historically we had thought that also meant that you had to submit evidence with your application of secondary meaning, that survey that shows association between the source and mark and other types of things, advertising expenditures and those sorts of things. But now perhaps don't need to do that study in view of what the federal circuit held in the Forney decision.

Dave Dalton:

That's an interesting narrative to watch I think. So we'll see what happens. Okay. Anna, as if 2020 weren't challenging enough, there were actually counterfeiting cases relating to COVID-19. This sounds bad and nefarious already, but some of this was relating to personal protective equipment or PPE, is that correct? What happened?

Anna Raimer:

That's right, Dave. Unfortunately in 2020, we did see some opportunistic bad actors that are seeking to profit from this global pandemic by selling counterfeit personal protective equipment or engaging in price gouging of that type of equipment. So as you can imagine, there's some significant public safety issues there, of course, as well as harm to a manufacturer's reputation about what these third parties are doing. So of course, issue received attention from law enforcement agencies. They increased efforts against this kind of COVID-19 related fraud and counterfeiting, but we also saw some brand owners take action too. Particularly what's interesting here was in the price gouging context. That's because under the first sale or exhaustion rule in trademark law, that the right to control the distribution of a trademarked product generally doesn't extend beyond the first sale of that product. So, that's how we have these resale shops and resale e-commerce platforms. So you can sell a good after you have purchased it, but that first sale doctrine doesn't apply where the genuine goods are so altered that they're considered to be materially different.

Anna Raimer:

Here we've had in the past, at least one Court of Appeal holding that different pricing in the products can constitute a material difference. And that's because this type of price gouging can reflect negatively on a brand owner. So you have consumers wrongly believing that the trademark owner is the one that's authorizing these sales to take unfair advantage of certain circumstances. And that impacts whether the consumers are willing to buy that product again, or purchase from that manufacturer if they think that's the conduct they engage in. So we see this material difference based on price argument receiving some traction in 2020 with these PPE cases and courts did grant injunctive relief from the resale of products at exorbitant prices. You can see how courts would be really upset about this type of conduct. One court, for example, said that no amount of money could repair the damage to a company's brand and reputation if it's associated with price gouging, which is the expense of healthcare workers and for first responders in the COVID-19 crisis.

Dave Dalton:

Oh. This could be a public relations disaster for a company if this goes unchecked, right?

Anna Raimer:

Oh, absolutely. And certainly if something like that's going on, you want to make sure you have your public relations team involved, and that's why we saw movement really quickly on these issues too, to go out and get temporary restraining orders and ensuring that consumers, public aren't thinking this is actually what the manufacturer was trying to do.

Dave Dalton:

Oh, geez. Well, so much for us all circling the wagons and getting through this crisis together. You hear about people doing things like that and it's discouraging. So, all right, so there's 2020. 2020 was exhausting, but let's look forward to 2021 and think about what we're expecting in the trademark arena moving forward. Anna, let's stay with you for a second. We got word that there are some fee increases either proposed or definitely on the way related to some trademark activities. What kind of fees are we talking about? What kind of increase in these fees, how do they work, what are the damages we're talking about here?

Anna Raimer:

That's right, Dave. Coming into effect January 2nd of 2021, and that's going to be the first fee adjustment in about three years by the trademark office. It's pretty much across the board and we're seeing it in application fees. Those are going to go up depending on the type of application about 25 to $75 per class. We're also going to see it in the post-registration fees. So when you have to file these periodic declarations to maintain your registration, those are going to go up $100 to $225 per class. And we're also going to see it in the trademark trial and appeal board context as well. So that's where you go to file your trademark oppositions and cancellation proceedings. There, we're seeing quite a significant raise in fees for petitions to cancel and notices of opposition. They're going to go up $200 to $600 per class and also with the extensions too.

Anna Raimer:

So while there's still not a fee for the first 30-day extension to oppose, if you file a second extension, a second 60-day extension or an initial 90-day extension, that fee is now doubled. So that's going to be $400 per application up from 200. And just the other last thing I wanted to note too, was that there was going to be a new fee for requests for oral hearings. And that's going to be $500 per proceeding. So some other fees are out there, but I'm just mentioning the ones that probably are most important to those out there thinking about when you want to file, when you want to renew and just keeping in mind for these cancellation and opposition proceedings, some of the fee increases that are going to take effect next year.

Dave Dalton:

See, there might be one good thing about 2020 to look back at. It's like at least those fees were lower back then. That, we had going for us in 2020.

Anna Raimer:

There you go.

Dave Dalton:

That's reaching for a silver lining, isn't it? One more thing. Again, looking out towards what's going to happen in 2021, Meredith, I think this is a big story. In fact, I see another podcast in our future about what we're about to talk about, but you'd sent me a note about, back in March, representatives from both chambers in Congress, the House of Representatives and the Senate introduced the Trademark Modernization Act of 2020, which would amend the Lanham Act, right? What would it do? And what's the current status? Because this sounds big to me.

Meredith Wilkes:

Definitely another podcast in our future on this one, Dave. Yeah. The Trademark Law Modernization Act is the first real substantial modification to the Lanham Act in some time. And it's newsworthy from the trademark standpoint in a lot of ways, but also just from a day-to-day real life perspective, we've got bipartisan support for legislation and in this climate, that's a huge deal. So we've got that to celebrate from 2020. But looking ahead, we're going to see three things I think transpire. I do think this will pass. One, it's going to give the trademark examiner some flexibility in terms of adjusting deadlines for responses and bring things in tune with the times. So that's a helpful mechanism. Second, a problem in the trademark office for some time has been what they call dead wood registrations or registrations that really aren't in use in commerce.

Meredith Wilkes:

And so this will create a couple different ways in which to get rid of some of this dead wood in a more cost-effective manner for people in the US who are trying to get their marks registered. So that's really helpful. And the third thing that it's going to do is it's going to change the law in some of the circuits right now. And it's going to restore the presumption of irreparable harm in Lanham Act cases, which is a big deal for trademark plaintiffs. So we'll be watching that one and fingers crossed, we get that passed in 2021.

Dave Dalton:

Yeah, I hope so. All sounds reasonable and doable. New administration, and some changes over on Capitol Hill, but hopefully calm heads prevail. And we'll see what happens there so we'll be watching that. We would be remiss and we're never remiss around here. At least we try not to be remissful if that's a word. We ought to talk about what the Women in IP initiative is planning for 2021. And I don't know what the Women in IP initiative is planning. That's a lesson to aspiring podcasters. Admit when you don't know something, but you know who does know? Meredith Wilkes and she's still here. So Meredith, talk about if you can, what plans are on the board, what you're hoping to do, what's confirmed, what your thinking is towards 2021, what the initiative might be doing.

Meredith Wilkes:

Lots of really great things in store for Women in IP in 2021. Really proud of our group, our team, our committee. We are now five years into programming, which I just I'm really proud of that. I think that's a big deal. In 2021, we've got at least four CLE programs that we're planning to deliver. One is a global view of litigating patent and validity. And so we're going to have colleagues on the line from the US, from Australia, from Germany. We haven't done anything like that before yet. So that's going to be a really cool offering in March of 2021. We'll do a leadership offering in June of 2021, and then we'll round out the year doing a brand update and also doing a patent update.

Meredith Wilkes:

And hopefully that patent update will talk about all the amazing therapies and vaccine development that have taken place since 2020. And so we're looking forward to that. First two offerings will be virtual only. We like to do these live in-person, but the first two for sure will be virtual. And then we'll see what happens for the September and November offerings. If we're lucky enough to do them live, we'll let folks know where we've picked in the United States to offer those. And if we go virtual, then that's fine too. But that's the plans at least for our CLE programs for 2021.

Dave Dalton:

The information will be imparted. The one on vaccines is going to be quite popular. There's a lot of interest out there. Even there will be close to a year from now, whatever happens. So it sounds like it's a well-thought out agenda. That's for certain. Hey, this is one of my favorites programs we do every year, catching up with you guys and looking forward to next year and everything. So thanks so much. I appreciate the preparation. It's always a very popular podcast, so thanks so much for your help. And you know we'll talk soon, right?

Meredith Wilkes:

Thanks so much for having us, Dave. We so appreciate it.

Dave Dalton:

Thanks, Meredith.

Anna Raimer:

Thank you.

Dave Dalton:

And thanks, Anna. Hey, best wishes for a great 2021. And we'll talk soon. Okay? You can find complete biographies and contact information for Meredith and Anna at jonesday.com. While you're there, be sure to visit our insights page where you'll find valuable content, including more podcasts, publications, newsletters, blogs, and videos. You can subscribe to Jones Day Talks at Apple Podcasts and wherever else quality podcasts are found. That way, you'll never miss a program. And finally, we at Jones Day Talks hope you and your family have a joyous holiday season, and we wish you all the best in 2021. Thanks as always for listening. I'm Dave Dalton. We'll talk to you next time.

Dave Dalton:

Thank you for listening to Jones Day Talks. Comments heard on Jones Day Talks should not be construed as legal advice regarding any specific facts or circumstances. The opinions expressed on Jones Day Talks are those of lawyers appearing on the program and do not necessarily reflect those of the firm. For more information, please visit jonesday.com.