JONES DAY TALKS®: Women in IP – AI and Copyright Law Need-to-Knows

Dave Dalton:

Every game-changing innovation or technological breakthrough brings with it great opportunities, but also very real legal risks and challenges. But artificial intelligence, AI, seems different. The stakes appear to be much higher, and the implications for intellectual property and copyright law seem especially complicated. We have Jones Day partners, Meredith Wilkes and Emily Tait here to help sort it all out, and they're always good, so you'll want to stick around. I'm Dave Dalton. You're listening to Jones Day Talks Women in IP.

Meredith Wilkes is a first chair IP trial lawyer. Clients say she has a gift for making complex IP concepts easy to understand. That's also why she's such a popular podcast panelist. For 25 years, she has focused on high stakes trademark, trade dress, trade secret, false advertising and design patent litigation matters for global brands and courts throughout the United States. She also counsels clients on brand protection strategies worldwide. Meredith chairs Jones Day's Women in IP initiative.

And Emily Tait is an IP and technology lawyer with experience in artificial intelligence and generative AI. She helps clients navigate the complex and evolving legal and regulatory AI environment, provides AI-related risk assessments and devises strategies to protect and enforce IP rights in the age of AI. She recently co-chaired the state of Michigan's Judicial Council's working group on Gen AI and is a leader of Jones Day's Global Autonomous Vehicles, AI and Robotics team. Meredith, Emily, thanks so much for being here today.

Meredith Wilkes:

Thanks for having us, Dave.

Dave Dalton:

Yeah, it's been a while, Meredith. I was starting to think maybe you found a cooler podcast or something. What's up?

Meredith Wilkes:

Never, never. It's nice to be back.

Dave Dalton:

Yeah. Well, we're going to talk about Women in IP and some of the things you've been working on, but we're going to talk about the intersection of AI and copyright law today. And to say that AI has made a splash everywhere, that would be a huge, huge understatement. But Meredith, this seems different and you've seen a lot and you've seen new technologies introduced and game-changing stuff and paradigm shifts and so forth. Why is AI so different, do you think? What's going on in the legal world that makes people really pause here?

Meredith Wilkes:

You always start with such a good question, Dave. And I agree with you, it's moving at lightning speed, and the question is, why is it different now? It comes down to two reasons, and I would put them in two buckets, subject matter and speed. Subject matter, meaning AI is covering everything. It's so expansive. It's touching healthcare, finance, IP. The breadth of the subject matter that it's reaching is nothing like we've ever seen before. And then the speed at which the developments are happening is unparalleled, how fast AI works, and then everything that it's able to do faster and faster and faster, and then all of the other new developments that come on as a result. So I would say subject matter and speed are really what differentiate what's going on right now.

Dave Dalton:

It always does come back to something, and this wasn't an original thought with me, but always occurs to me, the tech and the innovations are always way ahead of the law, the regulations, case law and so forth. I got to believe that's true again with AI, right?

Meredith Wilkes:

Lots of folks are saying that, lots of calls for modifying the various frameworks in which we exist in terms of IP protection and IP enforcement, both here in the US and abroad, lots of calls for all types of new and different regulation to be sure.

Dave Dalton:

Sure. You know who else knows a lot about this subject is Emily Tait, and Emily Tait's here. Emily, thanks again for being here today.

Emily Tate:

Of course. Thanks for having me.

Dave Dalton:

Let's talk about this a little bit more. What kind of concerns do clients have relative to AI or what are they asking you about as we sit here in early 2025? What's top of mind for them?

Emily Tate:

Yeah. Well, I think, as Meredith said, this issue of the technology evolving at light speed coupled with the changing legal framework and regulatory environment, et cetera, et cetera, it causes a lot of clients to just feel on edge, how to keep up with things and how to manage risk so as to be legal and ethical, but also how to take advantage of the incredible potential opportunity and efficiencies that AI could create. So I feel like there's been an evolution really since that first public release of ChatGPT back in November 2022. It seems like initially there was just a lot of fear because it was so unknown, so uncertain. Now it seems to be a shift towards, "Okay, we can't put the genie back in the bottle. How do we embrace these technologies, obviously doing it in a way that is managing the risks appropriately, making sure that a human is in the loop, et cetera, et cetera, but also taking advantage of the potential opportunity?"

So at a high level, that's the concerns I'm seeing. And then, of course, as an IP lawyer, a lot of questions about what does it mean for IP portfolios and IP assets? What is the human authorship requirement and copyright? And how much does a human need to be involved to maintain authorship of a work that's created? On the patent side, a lot of questions about the human inventorship requirement, and again, just this idea that there has to be a human inventor, but a human can be assisted by technology, including AI, so how to manage those considerations.

And then just a lot of questions about the possibility of infringement risk. An organization uses a particular tool, is the output of that tool going to infringe a third party work and how to think about that. So it is just a lot of questions. And then, of course, just new things, like deepfakes, which are exploding right now because AI makes the creation of deepfakes much easier. And so a lot of old questions within existing frameworks, but also new questions that these technologies have pushed to the forefront.

Dave Dalton:

Sure, sure. I was going to ask you about deepfakes in just a second, but getting back to where the clients are at right now, are you sensing a greater comfort level than there was back in late, like you said, 2022 ChatGPT? Are they more comfortable with the technology or at least what they think it can do for them and what the risks might be than they were?

Emily Tate:

Well, I don't know that I describe it as a comfort level, although I think that obviously that question, it really depends on the client, the organization. There are entities that are creators of AI models and also embracers of AI and technology. And so there might be a comfort level for those clients. And then there are still others that still really don't have a comfort level, if you will, still seems like a brave new world, very difficult to navigate, but an acceptance or a realization that the technology isn't going anywhere. And an increased sense that learning the technology and making sure humans are aware of what the technology is and making sure that that's implemented within the organization in a way that's minimizing risks, et cetera. But that also potentially maximizes the opportunity.

So I think I've seen an increase in that where it's like, "Look, we realize the technology is here to stay, and in fact is just continuously evolving." And so we as a business need to think about things that we can do with it, to maximize not only our operational efficiencies and what we're doing internally, but also to potentially service customers and clients of the business externally. So I think that comfort level really varies, but I think the increased level of acceptance and awareness of the technology has definitely been something that has increased over time.

Dave Dalton:

I wanted to circle back to deepfakes. You mentioned deepfakes a second ago. You were co-author of a publication that the firm pushed late last year about deepfakes. In fact, I'm sure Tom Kondilas, our producer, will provide a link to that publication for people interested. But Emily, for people who don't know, can you give us a quick overview of what we mean when we say deepfake in this context? And what are some of the attendant legal issues there?

Emily Tate:

Yeah, so a deepfake is also known as a digital replica. Sometimes you'll hear the term synthetic media, but it generally relates to an image or a video or audio recording that has been digitally created or digitally altered in a way that realistically but falsely depicts an individual or an entity. And people may have seen headlines involving this. Sometimes you have public figures. I believe there was a example last year where it was Pope Francis, there was a deepfake of him wearing a luxury puffer jacket, and it went viral. And people actually thought it was real, and then it came out that it was, of course, not real.

So other famous people, there's a video of Morgan Freeman, the actor, that is a video deepfake of him, but it is not really him. And it also mimics his voice, which is, of course, a very iconic and familiar voice. So things like that. And it's this digital spoofing, if you will. It's pretending to be something that it's not. And the legal concerns, of course, are concerns that fraud will be committed by using these technologies. And also concerns about the individual's name, image, and likeness being used in a manner that they have not authorized.

Dave Dalton:

There's potentially reputational damage there too, which is different area of the law, I understand, but there's all sorts of trouble to be found in this sort of thing.

Emily Tate:

Absolutely. Right. And that's where the name image likeness thing comes in because you could imagine any number of scenarios where somebody, their reputation is damaged. And this is happening also, you'll hear stories where things are being digitally created or digitally altered in a way to bully kids at school and things like that. So you see a range, obviously with public figures, but also private citizens being affected by the technology. And again, just the ease with which the technology can be used to perpetuate a deepfake.

Dave Dalton:

And Emily, that publication we've been referring to mentioned the possibility of federal and state regulations to address deepfakes in digital replicas. Any developments you want to talk about?

Emily Tate:

Yeah, so deepfake bills are a rapidly evolving area of legislative activity, and there really has been a lot of activity already. And I think we can expect to see that activity to continue, especially at the state level. I actually recently read that the number of bills addressing deepfakes has increased something like 950% in 2024 as compared to the previous five-year period, which makes sense given that the emergence and, in fact, the explosion of AI created digital replicas. So on the state level, we've already seen movement over 20 states, I believe it is, already have some laws enacted addressing deepfakes in particular contexts. Political communications and campaigning is a very sensitive area. And then even more than that, dates have enacted laws that are targeting the creation or distribution of deepfakes involving explicit sexual conduct. So these are areas where we've seen some activity.

Tennessee actually became the first state to enact legislation that specifically relates to the voices of songwriters and performers related to AI and deepfakes, and that's called the Elvis Act, and that went into effect last year. So a lot of interesting stuff and activity on the state level.

On the federal level, the Copyright Office and its report basically surveyed existing federal law and concluded that there was an urgent need for a federal law addressing deepfakes specifically. So that was the Copyright Office's conclusion and recommendation to Congress. And there's some interesting things going on there too. Actually, just this month, the bipartisan NO FAKES Act was reintroduced, and this would establish a federal framework to protect an individual's of publicity and is specifically addressing this rise of unauthorized deepfakes and digital replicas. So that's an interesting one because it has some bipartisan support and also has a diverse range of industry stakeholders who are supporting that piece of legislation. So it's anyone's guess in terms of whether that will be enacted, how long it'll take, et cetera, and there's a lot of wrinkles and gray areas that I'm sure will take some time. But as I said, this is an area where we've seen a lot of activity already, and we can anticipate that that activity will continue.

Dave Dalton:

Clearly, the technology has cut the attention of state legislatures everywhere.

Emily Tate:

Absolutely. And you see these headlines really it seems like every day there's new headlines involving problematic deepfakes affecting a whole variety of individuals. So it's an area where definitely there's quite a bit of momentum.

Dave Dalton:

Would it be too much to hope for in the current environment that this legislation might have bipartisan support? They would have to.

Emily Tate:

It's tough. Let's just say it's tough to predict what's going on right now, but I do think getting support is always a challenge here, it would certainly be, especially when you throw on top of it, that AI itself is really polarizing and people have really different views on to what extent it should be regulated. So I think it's just a very tough space. And in this political climate, I think it certainly would be difficult to imagine a scenario where there's much, much movement on this.

Dave Dalton:

We'll watch it, that's for sure. Let's go back to Meredith for a second. I think Meredith, Emily referred to the human authorship requirement for copyright protection, at least here in the United States. AI has raised a lot of questions relating to all that. Is there enough established case law to get a sense of where the courts might generally rule on this sort of thing when it comes to the human requirement?

Meredith Wilkes:

So Dave, you're taking us back to one of our early podcasts in May 2018, and we've got the band all back together. It was you and me and Emily and Tom in the Monkey See, Monkey Sue where we were talking about this.

Dave Dalton:

When Meredith and I were pushing notes back and forth getting ready for this, I said that was your exile on Main Street. That was your Sergeant Pepper. It was that good. That was your podcast, your legacy.

Meredith Wilkes:

But we started talking then about the notion of the human authorship requirement with respect to copyright protection. And if you went through the Copyright Act and read it word for word, nowhere in the act would you see that there's a human authorship requirement using those words per se. It's not defined that way, but there's enough in the act and there's enough dating back to the Jeffersonian grant in the Constitution that tells us that there has to be a human authorship component. And guidance from the Copyright Office has since confirmed as much.

We go article one, clause eight of the United States Constitution and it speaks to authors and inventors. Those are humans the last time I checked. And so there has to be that human component. And then if we look at in the Copyright Act and the case law interpreting and guidance from the Copyright Office, what's covered, what's protected by copyrights is the expression of ideas, not facts. And the last I checked, it's humans that can express ideas. And so we see in that respect why there's the human authorship requirement. This idea of the copyright ownership, it's a property, and again, only humans can own property. So it takes us back into that notion.

And if we look at also, too, how long it is that you hold copyrights, how long you have copyright protection, the statute speaks to the life of the author, and then some additional amount of time depending on some other things. So we see of the four corners and everywhere around that there is this human authorship requirement. Copyright Office has weighed in on it. The problem now, or the challenge is, with respect to AIs, how much human involvement is required to meet that human authorship requirement? How much? Is it enough that you put the prompts into AI? The extent to which the human needs to be involved is where this is going to be litigated.

So there've been a couple of recent cases where, the Thaler decision in particular, makes it very clear that if you just say AI is the author, that's not going to be enough. It seems like that was a test case, to see what the bounds were going to be and what the limits were going to be. And so this is going to continue to evolve.

Emily was talking about the reports, the three-part reports that were coming out of the Copyright Office. Earlier this year, the Copyright office did issue some guidance on the extent to which copyright protection would extend to AI works and human authorship. But this one is going to remain a constant state of flux because, and Emily alluded to this earlier, that there's this tension between balancing the innovation and pushing people to innovate versus protecting IP rights. And so it hits so many different competing issues. This one, there's no direct set of guidelines. You could go look at and say, "Okay, under this set of circumstances, absolutely yes, we're going to be able to get copyright protection." And pretty much the same is true on the negative side, so constantly evolving and the subject of a lot of commentary and I think this continued evolution in the Copyright Office.

Dave Dalton:

Sure. Let's talk about this some more. And Emily, you mentioned this earlier in your remarks, but I'm wondering about the practical implications in a workplace in terms of the human authorship requirement. And then Meredith had talked about, well, to what degree, how much input from the human was involved and so forth. This is like threading a needle, at least currently. How do companies deal with this requirement, Emily, on a day-to-day basis?

Emily Tate:

Well, again, I think this is something that really varies by the company, and I actually think the awareness of the requirement varies by the company. So companies that are very much content creators and involved in the world of copyright and manage their copyright assets closely, this is likely at the forefront of their minds and of their strategy. But a lot of companies, copyright is an afterthought. They've focused more on patents or trade secrets and copyright is this thing that's, "Yeah, we create content, but it's not as much of a focus of our business."

Sometimes that's because of the technology that they deal in. And then sometimes it's a reflection of the fact that copyrights exist upon fixation in a tangible medium, meaning that you or I can create a copyrighted work sitting here right now, and we have the copyright in it without having to do anything. You only go and do something with the Copyright Office to get a registration if... Well, some companies are very good about doing it practically, but oftentimes it's an afterthought, and you do it when you need to sue someone because you need a copyright registration generally to assert copyright infringement in US federal courts.

So oftentimes it's not until there's an infringement that there's the thought of, "Oh, I should probably go register the thing." So as a result of that, a lot of work is created with copyright not being at the forefront. And I think as a result of that, the awareness of the human authorship requirement varies. Now, having said that, I have seen companies address this in different ways. And again, this really is since generative AI took over as such a focal point. Because generative AI was the thing that made a lot of companies realize our employees and our independent contractors very well may be using these tools. And if they're using these tools, what does that mean for the works that these individuals are creating that we own by virtue of them being employees of ours or being contracted with us?

And so as a result of that, since the generative AI boom, there is a bit of a thought of, among some of the companies saying, "Okay, do we want our employees and contractors to even consider these tools if they're creating content for us?" And I've seen some companies take the position that, "No, for now we're banning these tools for the purposes of IP content creation." I've also seen companies where that's not the case at all, and in fact, they are embracing the tools as a means to create and enhance IP offerings. So I think it really varies by the organization.

And obviously if a particular company using these tools to create content, then the human authorship requirement is something that they absolutely need to be aware of to ensure that folks understand that the types of works that are unlikely to have protection because they've been created without sufficient human contribution to the expressive elements of that particular work. And then also to understand that AI can in fact be used as a tool to assist a human author. It very much varies by the company, but it is something that's awareness of the human authorship and how that fits in to IP strategy is going to be something we see just increased conversations about because it's a really interesting area that has a lot of uncertainty around it.

Dave Dalton:

Sure. And Emily, you're going to hate this question, but I'm going to ask it anyway. Who would monitor this? I know every company is different and organizational structures are different and so forth. Who would police this for, say, a big company, a large billion-dollar company?

Emily Tate:

Well, that's exactly the question. And I think it really depends on... Obviously you talk about policing, a lot of companies are having this concern of, "We've known that AI is out there. We've seen productive AI increasingly encroach upon our lives, but also in some ways enhance it, and maybe in some ways make us feel like we're being watched." There could be a good reaction to predictive AI and other types of AI and a negative reaction. But generative AI changed that conversation because suddenly the tools were in the hands of personnel that are charged with doing things such as IP creation for the company.

Given that, in terms of the policing, it largely depends on the organization and its structure. Do they have a generative AI use policy, things that are prohibited, things that are allowed, tools that are prohibited, tools that are allowed, et cetera? Because without that policy in place, then policing becomes an exercise in futility. How do you check to see people are doing things the right way if the right way hasn't even been defined for your organization? I think then obviously if you do have a policy like that, and again, depending on what your approach is to whether you're going to use these tools or not for the purposes of IP content creation or enhancement, that point a determination on what process you would follow to make sure people are doing it in the manner that's compliant. That's a whole other question, and I think a real challenge.

Dave Dalton:

Sure, sure. I wanted to bring up the Copyright Office again. In this country, in the United States, at least, is the Copyright Office the go-to source now for guidelines, regs such that they are and best practices even? Is that where companies should go for advice in terms of what they can and should do?

Meredith Wilkes:

They should go to Emily and talk to her.

Dave Dalton:

Yeah, of course.

Meredith Wilkes:

Listen to this podcast.

Dave Dalton:

I walked right into that.

Meredith Wilkes:

It's a good question, Dave, and so I'm going to give you the frustrating law school professor answer, which is, it depends. I will tell you to be sure, it is definitely a starting point. And if you don't know that on the Copyright Office webpage, there's a whole separate section devoted to AI. It's something that you should get familiar with. And Emily and I have both mentioned that there are a series of reports coming out on AI and copyright, and one, I think, is expected a little bit later this year on the legal implications of training AI models with copyrighted materials. And that's going to be huge. People are paying a lot of attention to that.

So the Copyright Office is one place, but also because of the uncertainty and because of some of the patchwork that Emily was mentioning earlier, you have to be watching the court decisions that are coming down, and particularly in the fair use space, the Warhol decision from last year, the Supreme Court's Warhol decision on fair use is one that folks are looking at a lot, and the appellate courts are now starting to utilize maybe in ways that nobody could predict when that decision came down and the Google, Oracle decision.

But the fair use, to me, is where a lot of these fights are going to be had in terms of what is and is not permitted fair use. And that is just dramatically different on who the players are and what is it that's being used, and is it generative AI or is it not? So that's the other place where we really have to be paying close, close attention is the fair use decisions and how those are aligning. And again, it's going to be patchwork unless and until there's some sort of more comprehensive federal legislation on point.

Dave Dalton:

Let's move offshore for a second. I'm going to ask you more about Women in IP in a couple minutes. But you put on a terrific webinar a couple of weeks back, and it wasn't just US AI, IP or copyright. We had one of our lawyers from Europe talking also. And again, this program today has been US centric, but looking back at that program from a couple weeks ago, anything from a European perspective that was markedly different than what we've talked about today? I'm just wondering if there are any flags you noticed.

Meredith Wilkes:

So Rebecca Swindells was on our panel, our Women in IP panel, and she's definitely one of our authorities in the UK and Europe on this issue. The thing that struck me and that resonated with folks who had tuned into the podcast was twofold. One, again, I talked for a minute ago about fair use and the fair use defense in the UK is much different and much more limited than it is in the United States. And so the litigation landscape and the defenses to infringement are going to be much different outside of the United States. But the other thing that probably woke a lot of people up or they walked away going, "Gosh, I had no idea this was even something that was being considered, or it's something that's in the works," is the idea that copyrighted materials can be used to train AI models with impunity, that there would be no infringement case if you were using copyrighted materials to train AI models, unless the copyright owner opts out and says, "No, you can't do it."

And part and parcel with that is some transparency required to tell the world, "Hey, we're using this, this, and this to train the AI models." But that, to me, really resonated with folks who maybe weren't aware because, again, this is another issue. What can you use to train these AI models and is it really copyright infringement or is it fair use? Some folks say, "Oh, it's no different than me going to the library reading a bunch of books, learning about what's in the books and then taking it and using it to apply to my day-to-day goings-on and creations of other things." But it's far more nuanced than that. It's far more complicated than that, but those are a couple of the really big takeaways in terms of difference. Potential for the extraterritorial application of those types of regulations could be pretty impactful because it's going to apply to the people who own that information in Europe, but it has ramifications outside of Europe, and I think that's another thing that folks who operate globally will want to be paying attention to as well.

Dave Dalton:

Sure, sure. And probably should do a program just on fair use at some point. I know the firm's published on it. We've put out at least one commentary I can recall recently, but I don't think we've done a podcast yet. Anyway, we'll put that on the side burner for now.

Emily Tate:

Yeah, that's a huge topic and super interesting, and unfortunately one that's also maddeningly fact-specific and very hard to predict, but certainly could warrant just an entire separate discussion.

Dave Dalton:

Yeah, yeah, that's right. I didn't mean to go so high level, but definitely. That's a big drill-down probably. A couple more questions, and you guys have been great and patient with your time and so forth. I always ask about takeaways, and we've covered a lot of ground here in a little less than a half hour, but I always try and ask, hey, what's one takeaway, either something that's been mentioned or something not someone tuning in listening to this, what's the one thing they ought to remember? I'm going to go to both of you for this, but maybe start with Meredith. Meredith, you mentioned quite a few topics, but is there anything in particular, this is the one key takeaway today to come away from this program with?

Meredith Wilkes:

The only constant is change, Dave. That's the copyright lawyer Full Employment Act adage right there. But that really is. This is a rapidly evolving area of the law. Trying to stay on top of it, trying to manage it is a big task. And I'll end where I started and say that the broad subject matter, coupled with the speed with which these things are developing, really it's changing, it's changing fast, and so the only constant is the change.

Dave Dalton:

Put that on a bumper sticker. Emily, what about it? What would you like to leave our listeners with today?

Emily Tate:

To me, a big takeaway is just to obviously understand and have that awareness of how immediately and profoundly disruptive AI is in the context of IP. And I feel like for companies and looking at their IP assets, copyright patents and trade secrets are all really, really important and all are being meaningfully impacted by AI, and so it can seem daunting to try to keep up with what's going on. It's almost impossible to really do so given how much everything's changing, but sometimes just backing up and taking inventory of what are the assets that we have, what are the key areas of growth that we envision, and how can we put into place a strategy that will look to both manage the risks associated with AI and GenAI, but also maximize our IP assets?

So I think having this holistic approach across the spectrum of IP assets is really important because AI is disrupting all of these areas.

Dave Dalton:

Definitely. And AI strategy, especially for a large multifaceted organization is a must, it sounds like. Thanks, but before we sign off, I want to ask about Women in IP. And I had a sneak preview of the calendar of what Jones Day's Women in IP group has planned for the rest of the year. But Meredith, if you want to run by our listeners what's coming up and where they can go for more information, that might be a great way to wrap this up today.

Meredith Wilkes:

Thank you so much, Dave. Yeah, really proud of the fact that we are in our 10th year of programming, and we started off the year with our artificial intelligence program that you were a part of that you got to tune into and that we've talked about in the podcast today. We've got three more CLE programs already on the books for 2025. We'll do our View From the Top Women Leadership program in June. We'll do a Woman in the Courtroom program in September. And then we're going to round out the year, and we might need to make this a six-part series at the speed with which things are happening right now, but the plan is to do an FTC, FDA, and IP 2025 in review because obviously there's a lot of overlap in those three areas.

And like I said, with the speed with which things are happening right now, we might have to make that the multi-program offering, but that's what we have planned for right now. Anyone who missed the artificial intelligence program that we offered last month, if you just email us at womeninip@jonesday.com, we can send you that recording, and I know it's available on a couple of our platforms, so we can certainly email that out to you.

Dave Dalton:

I don't know how you guys do all this. You guys are busy as it is with your day jobs as it were, being Top Gun lawyers, and then you're putting on webinars and your people are contacting you for information about how do I find that webinar. You guys do a great job. So I say it every time we talk, Meredith, Emily, it's always a pleasure. You guys are great. You know your stuff so well. Your programs do very well. The Women in IP series has been very popular and I'm sure it will be for a long time to come. So thanks so much for being with us today.

Emily Tate:

Thank you so much.

Meredith Wilkes:

Thank you so very much, Dave. Appreciate all the support.

Dave Dalton:

For sure, for sure. All right, let's do this again soon. You take care.

Meredith Wilkes:

Sounds great.

Emily Tate:

Bye-bye.

Dave Dalton:

For complete bios or contact information for Meredith Wilkes or Emily Tait, please visit jonesday.com. While you're there, check out our Jones Day Insights page for more podcasts, videos, commentaries, white papers, and other timely content. Subscribe to Jones Day Talks at Apple Podcasts or wherever else you find your business-focused podcasts. Jones Day Talks is produced flawlessly with no mistakes by Tom Kondilas. As always, we thank you for listening. I'm Dave Dalton. We'll talk to you next time.

Speaker 4:

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