U.S. Privacy Notice

For the visually impaired: Rutan & Tucker, LLP is committed to ensuring this Notice is accessible to individuals with disabilities. If you are visually impaired (or require this Notice in an alternative format) and need assistance accessing or understanding this Notice, you may contact us by telephone at 866-491-0580, and we will work with you to provide the information you need through an accessible method, consistent with applicable law.

Effective Date: January 1, 2026 

Introduction

Rutan & Tucker, LLP (“Rutan”, “the Firm”, or “we”/ “our”/ “us”) is a California-based law firm dedicated to serving the legal needs of individuals, businesses, and organizations. Our work spans a wide range of practice areas, and we are committed to providing our clients with professional, ethical, and effective representation. 

This U.S. State Privacy Notice (the “Notice”) describes how Rutan collects, uses, discloses, and otherwise processes personal information, and the privacy rights and choices available to individuals under applicable U.S. state privacy laws.

Scope and application

This Notice applies to personal information the Firm processes in connection with its business activities, including through our websites and online services, communications (including email and phone), marketing and business development activities, and our interactions with clients, prospective clients, vendors, professional contacts, and other individuals. This Notice also applies to personal information we may process in connection with events, seminars, and other Firm-related activities.

This Notice does not apply to personal information we process where a different privacy notice is presented (for example, a dedicated applicant/employee privacy notice), or where an exception applies under applicable law.

Professional obligations and legal services context

As a law firm, we are also subject to professional responsibilities and legal requirements. Certain information may be protected by legal privileges (such as the attorney-client privilege) or other legal doctrines, and we may be required to retain or use information to comply with applicable law, ethical obligations, or to establish, exercise, or defend legal claims. These considerations may limit how we respond to certain requests.

Data Processing Activities

The following describes the Firm’s personal information processing activities during the twelve (12) months prior to the Effective Date of this Notice. 

Categories of Sources

We collect personal information from the following categories of sources:

• Directly from you. For example, when you contact us, engage us for legal services, attend Firm events, subscribe to updates, complete intake or conflict-check questionnaires, submit forms on our websites, or otherwise communicate with us.
• From clients and others in connection with legal services. For example, when clients, opposing parties, witnesses, experts, co-counsel, insurers, courts, mediators/arbitrators, government agencies, or other relevant parties provide information in connection with a matter.
• Automatically through online interactions. For example, when you visit our websites or interact with our online platforms, we may collect information through cookies, pixels, server logs, and similar technologies (subject to applicable consent requirements).
• From service providers and vendors. For example, IT and security providers, cloud hosting and collaboration platforms, e-discovery vendors, marketing/CRM platforms, analytics providers, event management providers, and other vendors that perform services on our behalf.
• From professional contacts and referrals. For example, from other firms, professional networks, bar associations, referral sources, or other business partners.
• From publicly available and third-party sources. For example, public records, court filings, government websites, news sources, social media platforms (subject to your settings), and commercially available databases (such as for identity verification, due diligence, or conflict checks, as permitted by law).

Categories of Recipients of Personal Information

We may disclose personal information to the following categories of recipients, subject to applicable law and professional obligations:

• Affiliates and internal personnel. Firm partners, employees, contractors, and temporary staff with a need to know for business or legal-service purposes.
• Service providers and vendors. Entities that provide services to us such as IT support, cybersecurity, cloud hosting, communications, document management, e-discovery, litigation support, payment processing, analytics, marketing, and event management.
• Clients and matter-related participants. As necessary to provide legal services, including clients and their representatives, co-counsel, opposing counsel and parties, experts, consultants, investigators, and other participants in a legal matter.
• Courts, tribunals, and government entities. Including regulators, law enforcement, and other authorities where required or permitted, including in response to lawful requests.
• Professional advisors. Such as auditors, insurers, accountants, and outside counsel, where appropriate.
• Business transferees. In connection with a merger, acquisition, reorganization, financing, dissolution, or other business transaction involving all or part of the Firm (subject to confidentiality protections and applicable law).
• Other parties at your direction or with notice. For example, when you ask us to share information with a third party or where we otherwise provide you notice consistent with applicable law.

Our Purposes for Processing Personal Information

We process personal information for the following business and commercial purposes, organized by common Firm activities:

• Operations of our websites and other online platforms
  • Provide, maintain, and improve our websites and online services;
  • Personalize content, maintain session integrity, and remember preferences;
  • Conduct analytics and performance measurement;
  • Manage cookies and similar technologies, consistent with your choices and applicable law.
• Providing legal services and administering client relationships
  • Evaluate inquiries and determine whether and how we can assist (including intake, conflicts checks, and engagement administration);
  • Communicate with clients and others about matters;
  • Provide legal advice and representation, including case strategy, filings, discovery, and related services;
  • Maintain matter files, manage billing, timekeeping, and collections.
• Business operations and administrative purposes
  • Operate our day-to-day business (including finance, accounting, records management, audits, and insurance);
  • Maintain internal policies, procedures, and training;
  • Manage vendor relationships and procurement;
  • Support continuity planning and business management.
• Marketing, business development, and communications
  • Send newsletters, legal updates, event invitations, and other communications (where permitted);
  • Manage events, webinars, and Firm-hosted activities;
  • Track engagement with communications and improve outreach, consistent with applicable law.
• Safety, security, and fraud prevention
  • Protect the security and integrity of our systems, networks, premises, and personnel;
  • Monitor, detect, and prevent fraud, misuse, unauthorized access, and other security incidents;
  • Conduct security assessments, debugging, and incident response.
• Compliance with law and professional obligations
  • Comply with applicable laws, regulations, court orders, subpoenas, and lawful requests;
  • Satisfy professional and ethical obligations (including confidentiality requirements);
  • Establish, exercise, or defend legal claims, and manage disputes.
• Corporate transactions
  • Evaluate and execute corporate transactions involving the Firm (such as mergers or acquisitions), including related due diligence and transition planning, consistent with applicable law.

Deidentified and Aggregate Information

We may create, use, and disclose deidentified or aggregate information for purposes such as analytics, improving our services, security, and operational reporting. “Deidentified” information is information that cannot reasonably be used to infer information about, or otherwise be linked to, a particular individual, and “aggregate” information is information that has been combined so that it no longer relates to a single identifiable individual. When we maintain information in deidentified form, we will maintain and use the information only in deidentified form and not to attempt to reidentify it, except as permitted by applicable law; and will require our service providers, contractors, and other recipients (as applicable) to comply with restrictions on reidentification and to use the information only for permitted purposes.

Online Data Collection & Use

Without limiting any of the disclosures herein, this section describes how the Firm collects and uses information through its websites and other online properties (the “Online Services”). Our Online Services may incorporate third-party features and embeds that are operated by third parties. When these features load, your browser may connect directly to the third party’s servers, which may allow the third party to collect information about your device and your interaction with the feature (including IP address, device/browser information, referral URL, and information collected via cookies or similar technologies). These third parties use this information subject to contractual limitations and your settings. 

Tools We Use to Collect Information Online

The Firm and certain third parties may collect information through the Online Services using technologies such as:

• Cookies and similar technologies (e.g., first- and third-party cookies, local storage) to remember preferences and support site functionality.
• Pixels, web beacons, and tags to understand whether you interact with content (for example, to measure page views and campaign effectiveness).
• Log files and server-side data to collect information such as IP address, browser type, device information, operating system, referring/exit pages, date/time stamps, and site interaction data.
• Analytics tools to help us understand how visitors use the Online Services, improve performance, and diagnose technical issues.
• Embedded content and third-party features (e.g., map embeds, video players, social media widgets) that may allow the provider to collect information about your interaction with that feature, subject to your settings with the third party.

Depending on your device and settings, these technologies may collect information that constitutes “personal information” or “personal data” under applicable law, including internet/network activity information, online identifiers, and approximate location derived from IP address.

Analytics Tools Providers (including Google Analytics). We utilize various analytics tools, including Google Analytics, for detailed user interaction analysis. These tools collect data such as your originating location, visit frequency, viewed pages, and actions taken within our Online Services. These tools use cookies to collect this information. The use and sharing of this data by Google are subject to the Google Analytics Terms of Service. For options to opt-out of Google Analytics tracking, you may disable cookies on your browser or follow these specific instructions provided by Google.

How We Use Online-Collected Information

We use information collected through the Online Services for purposes such as:

• Operating the Online Services (e.g., enabling core features, maintaining session integrity, remembering preferences).
• Improving performance and user experience (e.g., analytics, troubleshooting, quality assurance).
• Security and fraud prevention (e.g., detecting malicious activity, protecting systems and users).
• Communications and marketing (e.g., measuring engagement with Firm communications, sending updates where permitted, and managing preferences).

We may also use deidentified or aggregate information derived from online activity as described in the “Deidentified and Aggregate Information” section.

Your Choices and Controls

You may be able to control certain online data collection and use through the following methods:

• • Cookie preference tools. If the Online Service provides a cookie banner, cookie settings tool, or a “Your Privacy Choices” / “Do Not Sell or Share My Personal Information” link, you may use it to manage certain categories of cookies and similar technologies.
  • Browser settings. Most browsers allow you to:
    • Block or delete cookies;
    • Receive a notice before a cookie is placed; and/or
    • Restrict certain types of storage.
      Please note that blocking or deleting cookies may affect functionality, and certain features of the Online Services may not work properly.
  • Device settings. Some devices permit you to limit ad tracking or reset an advertising identifier. These controls vary by device and operating system.
  • Email communications. If our emails contain tracking technologies (e.g., pixels) to measure open/click activity, you may be able to limit this through your email client settings or by unsubscribing from marketing communications (where applicable).

• Do Not Track signals. Some browsers transmit “Do Not Track” (“DNT”) signals. Because there is no uniform industry standard for DNT, the Firm does not respond to DNT signals. You can use the controls described above (including cookie settings and browser controls) to manage certain tracking activities.

Third-Party Links and Services

The Online Services may include links to third-party websites or services. The Firm is not responsible for the privacy practices of those third parties, and their practices are governed by their own privacy notices. We encourage you to review those notices before providing information to third parties.

Notice of Collection and Use

For ease of reference describe our personal data collection and use practices in more detail, below: 

Category of PI	Examples of Personal Information Collected and Retained	Categories of Recipients (Disclosures for Business Purposes; Sold/Shared)
Identifiers	Name; alias; postal address; email address; telephone number; online identifiers (e.g., cookie ID, device ID); IP address; account log-in credentials (if any); client/matter identifiers.	Disclosures for Business Purposes: IT/hosting and cybersecurity vendors; communications providers; CRM and marketing vendors; e-signature/intake vendors; clients (as appropriate); co-counsel/experts/vendors supporting matters; courts/tribunals; government entities (as required); professional advisors; insurers; payment processors (if applicable). Sold/Shared: Not sold. Not shared.
Personal Records	Signature; bank account/payment information (if paying Firm invoices); billing address; insurance information (where relevant to a matter); other information used for billing/engagement administration.	Disclosures for Business Purposes: payment processors and financial institutions (if applicable); accounting/billing vendors; IT/hosting vendors; auditors; insurers; professional advisors; clients and matter participants as needed for services; courts/government as required. Sold/Shared: Not sold. Not shared/
Protected classification characteristics (under California or federal law)	Information you provide or that is included in matter records that may relate to protected characteristics (e.g., race, ethnicity, religion, disability status, sex, gender identity/expression, marital status, age), to the extent relevant and permitted.	Disclosures for Business Purposes: clients (as directed/authorized); co-counsel; experts/consultants; e-discovery/litigation support vendors; courts/tribunals; government entities; professional advisors; IT/security vendors (subject to access controls).   Sold/Shared: Not sold. Not shared.
Commercial information	Records of products or services purchased/considered (e.g., engagement history, legal services requested); billing and transaction records; event attendance; marketing preferences.	Disclosures for Business Purposes: CRM/event management vendors; IT/hosting vendors; analytics providers; payment processors (if applicable); auditors; professional advisors.   Sold/Shared: Not sold. Not shared.
Internet Usage/Activity Data	Website/app interactions; pages viewed; referral URLs; search terms on our site; browser/device information; IP address; cookie identifiers; log data; email open/click data (where enabled).	Disclosures for Business Purposes: IT/hosting vendors; cybersecurity vendors; website support vendors; analytics providers; cookie management platform providers.   Sold/Shared: Not sold. Not shared.
Geolocation data	General location derived from IP address; location data you provide (e.g., office visit, event attendance). We do not typically collect precise geolocation unless you voluntarily provide it or it is necessary for a specific interaction.	Disclosures for Business Purposes: IT/hosting and cybersecurity vendors; analytics providers; event management vendors (as applicable).   Sold/Shared: Not sold. Not share.
Sensory data	Audio recordings of calls (where permitted and with notice); voicemail messages; photographs/video from Firm events or premises (where applicable and with notice); CCTV/security footage (where applicable).	Disclosures for Business Purposes: communications vendors; event vendors; security vendors; IT/hosting vendors; clients/matter participants where relevant; courts/government as required.   Sold/Shared: Not sold. Not shared.
Professional or employment-related information	Employer; job title; professional credentials; bar information; work history provided in communications; business contact details; references/referrals.	Disclosures for Business Purposes: clients and matter participants as needed; CRM vendors; IT/hosting vendors; professional advisors; courts/government as required.   Sold/Shared: Not sold. Not shared.
Education information (non-public) (FERPA)	Education records provided in connection with a matter or engagement (e.g., transcripts or similar records), if applicable.	Disclosures for Business Purposes: clients/matter participants; co-counsel; experts; e-discovery/litigation support vendors; courts/tribunals; government entities as required; IT/hosting vendors (subject to controls). Sold/Shared: Not sold. Not shared.
Inferences drawn from other personal information	Preferences and interests (e.g., practice-area interests inferred from interactions); communication preferences; inferred relationship type (client/prospect/vendor); risk/security signals (e.g., anomalous login indicators).	Disclosures for Business Purposes: IT/security vendors; analytics providers; CRM/marketing vendors; professional advisors (as needed). Sold/Shared: Not sold. Not shared.
Sensitive Personal Information	Government ID numbers (where necessary); account log-in credentials; precise geolocation (rare); contents of certain communications where you choose to provide; information concerning health or disability (if relevant to a matter); race/ethnicity/religion/union membership (if relevant); biometric identifiers (if any).	Disclosures for Business Purposes: clients/matter participants (as authorized); courts/tribunals; government entities; co-counsel/experts; e-discovery/litigation support; IT/security vendors (subject to strict controls); professional advisors; insurers (where appropriate).   Sold/Shared: Not sold. Not shared.

Depending on the context of our interactions with you and the nature of the services requested or provided, the Firm may collect or process additional types of personal information that are not specifically listed in the chart (for example, information you choose to provide in communications, information necessary to evaluate or provide legal services, or information contained in documents and records related to a matter). If we collect or process personal information that is materially different from what is described in this Notice, we will provide any disclosures required by applicable law, and where required, obtain consent before processing such information. In all cases, any additional personal information will be processed consistent with this Notice, including for the purposes described herein, subject to applicable legal and ethical obligations and any restrictions imposed by law.

Retention of Personal Information

We retain personal information for as long as reasonably necessary to fulfill the purposes described in this Notice, including to provide legal services, operate our business, maintain accurate records, comply with applicable laws and professional obligations, and to establish, exercise, or defend legal claims.

Retention periods vary depending on factors such as the nature of the information, the context in which it was collected, the sensitivity of the information, whether we have an ongoing relationship with you, and applicable legal, regulatory, ethical, accounting, or contractual requirements. For example, information in client and matter files may be retained in accordance with our professional responsibilities and recordkeeping practices, which may require retention after a matter is closed. When personal information is no longer required for these purposes, we will delete, destroy, or deidentify it in accordance with our retention and disposal practices, unless retention is required or permitted by law.

Consumer Rights and How to Exercise Them

This section describes the privacy rights that may be available to you under applicable U.S. state privacy laws. The Firm will accept requests from any individual; however, where a particular law does not apply to the Firm or does not provide a right to you in your jurisdiction or circumstances, the Firm may, in its discretion, deny the request (in whole or in part) or provide a more limited response. In addition, as a law firm, the Firm’s ability to honor certain requests may be limited by legal privileges (including attorney-client privilege), attorney work product protections, duties of confidentiality, professional responsibility obligations, court orders, and legal retention requirements.

Privacy Rights That May Be Available To You

Depending on your state of residence and the Firm’s legal obligations, you may have the following rights:

• Right to Know/Access/Portability. You may request confirmation of whether we process personal information about you and request access to that personal information. Access may be limited where information is protected by attorney-client privilege, attorney work product, confidentiality obligations to clients or others, court rules/orders, or where disclosure would compromise legal strategy, security, or the rights of third parties. We may also redact information or provide a summary where necessary. You may also request to receive your personal information (or a copy of it) in a portable and, to the extent technically feasible, readily usable format.

• • • For California Residents: Under the CCPA, the right to know/access includes the right to request certain disclosures about our practices (such as the categories of personal information collected, categories of sources, purposes for collection, and categories of recipients), and may also include access to the specific pieces of personal information we have collected about you.
  • Right to Delete. You may request deletion of personal information we maintain about you. We may decline or narrow deletion requests where retention is necessary to provide legal services, comply with law and professional obligations (including recordkeeping), preserve matter files, maintain privilege and confidentiality, detect and prevent fraud or security incidents, comply with legal holds, or establish, exercise, or defend legal claims. In some cases, we may deidentify information instead of deleting it.
  • Right to Correct. You may request correction of inaccurate personal information we maintain about you, taking into account the nature of the information and the purposes for which it is processed. We may limit correction where the information must be maintained as part of an official record (e.g., timekeeping, billing, compliance records), where we cannot verify the requested change, or where changing the record could conflict with legal obligations or the integrity of a matter file. We may note a dispute or provide a supplemental statement where appropriate.

• Right to opt out of Sale or Share for Targeted Advertising. You have the right to opt out of the “Sale” or “Share” of your personal information, or opt-out of its use for “Targeted Advertising” (as those terms may be defined under applicable law). However, the Firm does not Sell or Share your personal information, or process it for Targeted Advertising. We also do not knowingly Sell or Share the personal information of consumers under 16.

The limitation of Selling and Sharing of personal data does not prevent us from disclosing personal information to service providers/contractors for business purposes, or from disclosures necessary to provide legal services, comply with law, maintain security, or otherwise operate our business consistent with applicable law. Likewise, the following are not considered a “Sale” or “Sharing”: (a) disclosures made to others at your direction; (b) disclosures made as part of a corporate transaction (described above); (c) disclosures made within the Firm; and (d) disclosures required or permitted by applicable law. 

Opt-out Preference Signals. Som U.S. privacy laws require businesses to process opt-out preference signals (such as the Global Privacy Control (GPC)) as a request to opt out of Sale or Share for Targeted Advertising for the browser/device that transmits the signal (and, where feasible, the associated user). While our website may receive the GPC signal and notify you if it has been processed, we do not process it for opt-outs of Sales and Sharing because we do not Sell or Share personal information. 

• Right To Limit Use and Disclosure Of Sensitive Personal Information. We only process Sensitive Personal Information for purposes that are exempt from consumer choice under U.S. Privacy Laws. We may use or disclose sensitive personal information as necessary to provide legal services, comply with law and professional obligations, maintain security, prevent fraud, and for other permitted purposes under applicable law.

• Rights to Restrict Automated Decision-making.  We do not engage in automated decision-making that would require notice or opt-in or opt-out under applicable U.S. privacy laws.

• Right to Non-discrimination. You have the right not to receive discriminatory treatment for exercising your privacy rights. The firm will not discriminate or retaliate against you for exercising your privacy rights. 

• Right to Appeal. Some U.S. privacy laws provide the right to appeal a refusal to take action on a request. Appeals are reviewed in in light of the applicable law and the Firm’s legal and ethical obligations, privileges.

How to Submit a Request

You or your lawfully designated agent may submit a request to exercise your privacy rights by emailing us at privacy@rutan.com or calling (toll free): 866-491-0580. In your request, please include: (i) your full name, (ii) the state where you reside, (iii) the nature of your request (e.g., access/know, delete, correct), and (iv) sufficient detail for us to locate the relevant information (for example, the email address used to communicate with us and the approximate timeframe of your interactions).

You may appoint an authorized agent to submit certain requests on your behalf. We will require proof that the agent is authorized to act for you and may also require you to verify your identity directly with us and/or confirm that you provided the agent permission to submit the request.

How We Process Requests

1. Intake. Upon receipt, we will log your request, determine which law(s) may apply based on your residency and the context of our interactions, and identify any legal, ethical, or professional obligations that may limit or shape our response (including attorney-client privilege and confidentiality obligations).
2. Verification of Identity. To protect your information, we will take reasonable steps to verify your identity before responding to certain requests (such as access/know, deletion, or correction). Verification steps may include: (a) Matching information you provide (e.g., name, email address, phone number, matter reference, interaction timeframe) to information in our records; (b) Requesting additional information only as reasonably necessary to verify you; and/or (c) Using a risk-based approach depending on the sensitivity of the information requested. If we cannot verify your identity (or the authority of an agent), we may deny the request or limit the information we provide.
3. Processing. We respond to verifiable consumer requests within the timeframes required by applicable law. For example, California generally provides 45 days to respond to certain requests, with a permitted extension (typically up to an additional 45 days) when reasonably necessary and with notice. We will notify you before the end of the initial statutory deadline if we need additional time to respond. 
4. Response. We may respond to your verifiable consumer request by providing the requested information or taking the appropriate action (e.g., deletion or correction) and providing you with notice that we have done so. We may deny a request (in whole or part) where permitted by law, including where: (a) We cannot verify identity or agent authority; (b) The request is subject to an exemption or exception (e.g., privileged/confidential information, compliance and recordkeeping obligations, security, fraud prevention, or legal claims); or (c) The Firm is not subject to the asserted law and elects, in its discretion, not to honor the request. We will explain the basis for our decision to the extent required by applicable law.
5. Appeal. If your request is denied, and where applicable law provides you such a right, you may appeal by contacting us at privacy@rutan.com with the subject line “Privacy Rights Request Appeal” (or by calling 866-491-0580). We will review and respond to appeals as required by applicable law. 

Limitations on Our Responses

In handling personal information and responding to privacy requests, the Firm will act in a manner intended to comply with applicable law and to protect the rights and interests of others. Accordingly, we may deny, limit, or condition a request where fulfilling it would (i) violate applicable law, court rules, or professional responsibility obligations; (ii) impair legal privileges or confidentiality obligations; (iii) interfere with the Firm’s ability to provide legal services; (iv) compromise the security or integrity of our systems; or (v) adversely affect the rights, privacy, or safety of other individuals, including our clients, personnel, and third parties. Where feasible and permitted by law, we may provide a partial response, redact information, or provide information in an alternative form to address these considerations. In responding to privacy requests, we may take steps and apply limitations that are permitted by applicable law and appropriate to protect individuals, our clients, and the Firm. For example:

• • Security and fraud prevention. We may deny or limit a request if we cannot reasonably verify your identity or authority, if fulfilling the request would create an undue risk of fraud, identity theft, or unauthorized access, or if we must take additional steps to safeguard personal information.
  • Protection of privileged and confidential information. As a law firm, we may withhold, redact, or decline to produce information that is protected by the attorney-client privilege, attorney work product doctrine, duties of confidentiality, court rules or orders, or that would adversely affect the rights and freedoms of others.
  • Repeated or excessive requests. We may limit the frequency of responses, decline to respond to requests that are manifestly unfounded, excessive, repetitive, or that request information beyond what is required by law, or provide a more limited response where permitted.
  • Disproportionate effort or technical feasibility. Where allowed, we may decline to take action or may narrow the scope of a request if fulfilling it would require disproportionate effort, would be technically infeasible, would compromise the security or integrity of our systems, or would require us to retain additional information solely to identify you.
  • Fees and cost considerations. Where permitted by law, we may charge a reasonable fee (or decline the request) if it is manifestly unfounded or excessive, or if applicable law otherwise allows fees (for example, for certain duplicative requests). If a fee applies, we will explain the basis and provide an estimate before proceeding.

• Legal and operational constraints. We may retain information as required or permitted by law (including record retention requirements, legal holds, and compliance obligations), and we may provide responses in an alternative form (e.g., through secure delivery methods, summaries, or redactions) to address security, confidentiality, and legal requirements.

Where we deny a request or limit our response, we will explain the reason to the extent required by applicable law.

Additional Notice for California Residents

California “Shine the Light” Disclosure

The Firm does not disclose “personal information” (as that term is used in California’s “Shine the Light” law, Cal. Civ. Code § 1798.83) to third parties for the third parties’ direct marketing purposes. If you are a California resident and would like more information about the Shine the Light law and how it applies, you may contact us at the mailing address provided below. Please include a “California Shine The Light Request” in your correspondence and include a return mailing address. Requests sent other than as specified may not be processed.

Contact Us

For general questions about this Notice, you may contact us as follows:

Office of Privacy Counsel

Rutan & Tucker, LLP

18575 Jamboree Road, 9th Floor

Irvine, CA 92612