If you started your legal career more than 30 years ago in the Securities and Exchange Commission’s (SEC’s) Enforcement Division by suing a company offering geographical dental licenses on the theory they are “investment contracts” and thus “securities” subject to registration under the federal securities laws,* you learned a few things.
Among them are invaluable insights and perspectives that can help startup businesses utilizing blockchain technology or seeking to raise funds to build projects and communities with their tokens or cryptocurrencies: and that’s knowledge lawyers without this expertise and experience might overlook or not fully comprehend.
One thing is certain, though. All businesses interact daily with the law in their operations, so they need someone to advise them on those interactions. This is especially true for businesses in newly emerging industries, where the laws governing these industries are often undeveloped.
New industries generally do not have the benefit of legal precedent to guide conduct or experience with its effectiveness and usefulness. This leads to uncertainty, unpredictability or, worse, unintentional violations of law.
Thus, pioneers and entrepreneurs in these new industries often require, in effect, an “outside general counsel” with considerable experience and specialized legal knowledge in several areas of the law to guide them.
The Emerging Blockchain Space
Blockchain technology is one such newly emerging industry. As with many emerging industries, those who seem to be attracted to the benefits of a new technology are generally younger. They work in and adapt to rapidly evolving nontraditional business environments, such as WeWorks and other shared spaces, which provide a more relaxed approach to generating business ideas. As blockchain technology’s younger generation moves the industry forward, they often lack exposure to traditional legal regimes that govern the corporate world.
This situation is consistent with blockchain’s nature. Blockchain technology “disrupts” traditional systems. It is a decentralized system, where disparate groups interact peer to peer to validate transactions without third-party intermediaries. Financial institutions, like banks that traditionally intermediate economic transactions, are absent from the blockchain universe.
Thus, some participants in the blockchain space might think that they are similarly ungoverned by traditional institutions and their rules and regulations when conducting their businesses. They might assume that the only laws they will have to understand are technology-related, and they retain counsel with only that expertise.
But blockchain technology implicates various U.S. laws in perhaps unexpected and adverse ways. Accordingly, individuals and businesses in the industry either must understand this or face disastrous consequences for their businesses and reputation if a governmental investigation or action is commenced against them for violations of law.
This article focuses on several legal areas that should be considered by businesses in the blockchain technology space.
These include corporate structuring and tax law, securities offerings and regulation, intellectual property, advertising, data privacy, and employment and labor.
While the legal areas that touch blockchain are not limited to this list, counsel advising blockchain technology businesses should at a minimum be knowledgeable in these fields.
Corporate Structuring and Tax Law
Blockchain technology businesses should consider a legal counsel’s advice in the corporate formation for their projects. While businesses in any industry need to consider corporate structure, more established industries follow well-known rules when making such decisions. Startup industries like blockchain technology, however, face unique legal and tax considerations and can benefit from the assistance of qualified counsel with an understanding of the foundational principals behind blockchain technology.
At times, those starting these blockchain technology projects do not even consider the traditional organizational forms for entities, such as corporations, limited liability companies or partnerships. They do not consider whether the entity will or should remain closely held if it’s successful in a few years or whether the entity will have a public offering of its securities or tokens. Some eschew the limited liability advantages for its founders/shareholders/members of forming a limited liability corporation. Rather, many blockchain technology projects operate as “foundations.”
For example, the Kin Foundation, behind the popular Kik app, operates the blockchain-based “Kin ecosystem.” The Kin Foundation and Kik Interactive are responsible for the release of Kin tokens, a cryptocurrency that does not require mining but is instead “earned through participating in surveys [and] engaging with apps within Kinit.” Kik developed Kin so that consumers could directly “reward” content creators on the network without traditional boundaries.
Another example is the Switzerland-based Libra Association, which was created by Facebook and 27 other members, including Visa, Mastercard, Paypal, Uber and eBay. The Libra Association will serve as the governing body providing oversight of the Libra blockchain, currency and reserve. The Switzerland-based Tezos Foundation similarly governs the Tezos blockchain. The Tezos Foundation “empower[s] persons and entities … to create a robust and decentralized digital commonwealth” while overseeing the responsible use of its assets. The Ethereum Foundation governs Ethereum, which uses blockchain technology to cut out internet third parties.
Projects like these that hold themselves out as foundations and associations demonstrate a new business approach to commerce that is not dependent upon traditional financial systems and currencies. They show that blockchain businesses do not fit the traditional corporate mold. Attorneys in the blockchain space must consider and understand the implications of such a business model in order to provide meaningful and valuable counsel.
But they also should advise their clients about the benefits of qualified small business stock under Section 1202 of the U.S. Internal Revenue Code. This section provides generally that if shareholders who purchase shares directly from a start-up corporation with less than $50 million in gross assets and hold them for at least five years, all profits up to $10 million on the sale of those shares by each individual shareholder is tax-free. Given this considerable tax advantage, it is something worth considering for blockchain start-ups.
Another corporate structuring consideration is location. Blockchain technology organizations should organize in blockchain-friendly locations. The blockchain technology industry is international and knows no sovereign boundaries, as transactions occur almost instantaneously and globally.
Several of the most prominent and/or rapidly growing blockchain technology organizations are based outside the United States. Hero, which uses blockchain technology “to provide a transparent loan marketplace,” is based in Barcelona. Japan leads in adopting progressive blockchain technology policies. As with the proposed Libra currency, Switzerland has become “a friendly jurisdiction for the ‘foundation’ model to govern ICOs [initial coin offerings].” Switzerland has approximately 530 blockchain start-ups in its “Crypto Valley” between Zurich and Zug. Smaller countries, like Singapore and Malta, are hot spots for blockchain technology businesses.
However, if you retain employees here in the U.S. or offer goods and services made here, your organization may still be subject to U.S. payroll and other income taxes.
Blockchain technology organizations in the U.S. face a less hospitable and predictable climate than their foreign counterparts do. They must coexist with traditional financial institutions, which blockchain seeks to eliminate from the transactions. U.S. banks show varied degrees of friendliness to and concern for blockchain and cryptocurrency, in particular because of the heavily regulated aspects of their industry.
Because of the need to ensure that anti-money laundering and know-your-customer regulations are rigorously observed, blockchain technology businesses in the U.S. sometimes have difficulty accessing traditional financial services. Bloomberg Business reported in March that cryptocurrency companies still have trouble opening corporate bank accounts. According to Sam Bankman-Fried, CEO of Alameda Research, “the standard answer of ‘just go to your local Chase branch’ does not work in crypto.” He believes that banks do not want to face the compliance issues surrounding cryptocurrency.
Switzerland faced this problem last year when government regulators cracked down on blockchain technology businesses. In response, Swiss banks “actively explored various ways to make it easier for blockchain companies to open corporate bank accounts.” The Swiss Bankers Association issued guidelines to facilitate their opening corporate bank accounts.
Until American institutions take similar steps, blockchain organizations in the U.S. might have difficulty accessing essential financial services.
Blockchain companies must remain vigilant about U.S. federal and state securities laws.
The securities laws regulating blockchain transactions and cryptocurrency are numerous and still somewhat unclear. There are federal laws regulating the offering of cryptocurrencies deemed to be “investment contracts” and “securities” as well as those implicating the registration of broker-dealers that offer and sell securities or cryptocurrencies for themselves or issuers, and of the registration with the SEC of securities exchanges.
Blockchain organizations must determine whether their tokens or business activities are subject to securities laws; if so, which ones; and how to either comply with federal registration or get an exemption from such laws. They must consider other federal laws requiring the registration of digital asset exchanges, which are likely considered “money services businesses” under the Bank Secrecy Act. These businesses must establish anti-money laundering programs and procedures and file reports of suspicious activity with the Financial Crimes Enforcement Network, a bureau of the U.S. Department of the Treasury.
Similarly, states too have laws regulating securities, banking and investments. For example, New York state requires “money transmitters” of digital assets to register with the state and obtain a BitLicense. It is important to seek out counsel with wide expertise in this field, as the consequences of violations of these federal and state laws can be severe. A government investigation or action can cause significant economic and reputational damage to your project.
But fortunately, there is some governmental guidance.
In April, the SEC released a framework for determining whether securities laws apply to digital assets. The framework applies the Supreme Court’s decision in SEC v. Howey Co. to analyze whether a digital currency is an “investment contract,” a type of security. This multifactor framework is not binding law. Not one of the test’s factors is dispositive. If nothing else, it is now clear from this release that the SEC will likely find that most tokens issued in Initial Coin Offerings are securities. This is consistent with its actions since the summer of 2017, when after the issuance of the DAO Report it brought enforcement actions against dozens of companies and individual defendants for violations of the registration provisions of the federal securities laws.
SEC Commissioner Hester Peirce criticized the agency in May 2019 for not providing firmer guidance. Peirce said that while the guidance is a step in the right direction, the Howey test might “raise more questions and concerns than it answers.” Peirce believes that the framework guides only “seasoned securities lawyers” and that the SEC’s “Jackson Pollock approach to splashing lots of factors on the canvas without any clear message leaves something to be desired, so we still have work to do in clarifying what factors are most important in making that determination.”
While her points are well taken, the SEC does deserve credit for making clear (implicitly) that it will likely go after only those issuers and participants in ICOs that continued after the issuance of the DAO Report in July 2017 or when fraud is also involved.
Despite the legal questions surrounding SEC regulation of blockchain and cryptocurrency, the SEC is not slowing down enforcement actions against the industry. In early June 2019, the SEC sued Kik for illegally offering $100 million in digital tokens during its 2017 ICO. Steven Pelkin, co-director of the SEC’s enforcement division, said that “by selling $100 million in securities without registering the offers or sales, we allege that Kik deprived investors of information to which they were legally entitled, and prevented investors from making informed investment decisions.”
Kik started a crowdfunding campaign called “Defend Crypto” to raise litigation funds. Kik CEO Ted Livingston said, “This is the first time that we’re finally on a path to getting the clarity we so desperately need as an industry to be able to continue to innovate and build things.” The lawsuit’s outcome could potentially show when an ICO does not meet the Howey test. Livingston’s comments show that those in the industry are hoping for this clarity. Until then, blockchain technology organizations facing securities regulation and SEC enforcement actions need experienced securities lawyers by their side.
The SEC and the Financial Industry Regulatory Authority (FINRA) have expressed concerns about digital assets and offering them to the public over the past two years. The concerns range from the manner of the offering, custody issues for the tokens, liquidity, and possible manipulation and fraud. They recently issued a joint statement on July 8 addressing the ways in which the federal securities laws and FINRA rules apply to intermediation of transactions in and custody of digital assets, focusing on custody and broker-dealer books and records concerns.
Thus, for the foreseeable future, there is little likelihood anyone will see the SEC approving a full-blown registration statement allowing a company to make a public offering of digital assets to retail investors. Thus, blockchain companies will have to consider whether to raise capital through a Regulation A (Reg A+) or a Regulation D offering. 
Regulation A (A+) and Regulation D
Reg A+ offers a type of exemption from full registration that is still submitted to the SEC for review and approval. It permits a company to raise up to $50 million in funds from retail investors, whether accredited or not. Once the offering is complete, Reg A+ securities or tokens are immediately tradable. However, a Reg A+ offering that seeks to raise between $20 million and $50 million is available only for projects that can produce two years of audited financial reports to investors.
Regulation D is another registration exemption, meaning it permits companies to offer securities without having to register with the SEC. Under certain advertising limitations, Regulation D provides a safe harbor for private offerings to an unlimited amount of accredited investors and to 35 nonaccredited investors. An accredited investor is usually either a bank or a business with more than $5 million in investable assets or a natural person with annual income of more than $200,000 or a net worth exceeding $1 million.
Rule 506 of Regulation D provides two exemptions, under 506(b) and 506(c); 506(b) does not allow general advertising of the offering to the public, and by contrast, 506(c) permits general advertising. However, 506(c) requires that the company offer its securities only to accredited investors and “take reasonable steps to verify” that they are accredited. Whether the company offers and sells securities under 506(b) or 506(c), the securities are “restricted” and cannot be sold for up to six months to a year without registration.
On July 10, the SEC approved a Reg A+ offering for a blockchain start-up for the first time. The SEC permitted Blockstack to make a $28 million offering that will give investors utility tokens that they can use as currency on the Blockstack network. The next day, the SEC approved another Reg A+ offering for startup YouNow, which will offer Ethereum-based tokens. These offerings will guide other blockchain startups looking to hold offerings in the future. However, whether a blockchain startup pursues a Reg A+ or a Regulation D offering, legal counsel with securities experience can help it navigate its fundraising efforts.
One final point worth noting in this area is insurance.
If your blockchain business plans to raise funds by means of a traditional securities offering or through the sale of digital tokens, directors and officers insurance should be considered. Similarly, if your blockchain business will be involved in raising the capital or be an exchange for digital assets, strong consideration of adequate insurance policies is advisable.
Intellectual Property Law
Intellectual property is another area that requires consideration, as those in the blockchain industry should protect their innovations. Blockchains can be either “permissionless” or “permissioned,” and the difference raises questions about a blockchain’s ownership.
A permissionless blockchain is a public blockchain, and anyone can be a part of it. These blockchains are usually more decentralized than permissioned blockchains. Permissioned blockchains, by contrast, are private and require permission to join. So, who owns the blockchain? It seems many people and companies claim ownership.
Blockchain-related patent applications have risen every year for the past several years. According to the Korean Intellectual Property Office (KIPO), 27 blockchain-related patent applications were filed in the U.S., China, the EU, Japan and South Korea combined in 2013. In 2017, that number jumped to 1,248. Today, a search of “blockchain technology” in the U.S. Patent and Trademark Office patent application database produces 2,507 hits.
Bank of America is said to have filed more than 400 blockchain-related patents. But even with the rise of patent applications, blockchain-related patents are not necessarily easy to obtain under U.S. law.
If a blockchain-related patent is challenged in court, federal courts might look to the U.S. Supreme Court’s decision in Mayo Collaborative Services v. Prometheus Laboratories, Inc. There, the Court created a four-part test to determine whether property is patentable. According to one American Bar Association article, a challenged blockchain-related patent would likely fail the Mayo test because blockchain technologies are “abstract ideas” and not “novel” and “nonobvious.”
The questions of ownership in permissionless blockchains, the rise in blockchain-related patent applications and questions regarding whether blockchain technologies can be patented under Mayo show that blockchain businesses need legal counsel with wide legal knowledge.
Blockchain technology also implicates advertising and consumer protection law. In 2018, the Federal Trade Commission (FTC) created an internal blockchain working group. Since then, the FTC has brought several anti-fraud actions against blockchain technology companies. These cases usually involve cryptocurrency, where businesses profit off of tokens but do not deliver agreed-upon goods or services.
The FTC stressed that it is investigating new forms of fraudulent activity in the blockchain industry. The FTC emphasized that it is not investigating merely “old schemes dressed up.” Rather, these schemes “actually use cryptocurrency and blockchain technology as a core part of the fraud.” Blockchain organizations need counsel to advise them on advertising practices on their websites and used in their businesses that do or could run afoul of FTC regulations.
Data Privacy Law
A business that conducts itself entirely online needs an online platform. In the blockchain world, consumers use an online platform to make transactions. But online platforms do not provide just goods and services to their users; they also gather and store their users’ data.
Blockchain organizations must acknowledge their consumers’ privacy interests and create policies to govern processing, management and protection of user data. They should alert consumers to their policies through terms-of-use sections on their website and ensure that the consumers agree to them.
While blockchains protect certain underlying data, the record of blockchain transactions is public for all to see. Blockchain technology also does not allow deletion of data; one of its features is immutability. However, certain privacy laws require some financial organizations to permanently delete data under court order. As blockchain technology currently exists, it would be impossible for blockchain organizations to comply with these laws.
New data privacy laws could also impact the blockchain industry. For example, the EU’s General Data Protection Rule (GDPR) went into effect in May 2018. Blockchain organizations in the U.S. might not think that the GDPR applies to them if they do not conduct business in the EU. However, the transborder realities of electronic data management and processing make it impossible for businesses worldwide to avoid the GDPR’s impact. The GDPR is extraterritorial because it applies to all businesses, regardless of location, as long as they process the personal data of EU residents.
U.S. data privacy laws are developing. The California Consumer Privacy Act (CCPA) will take effect on Jan. 1, 2020. This law will change the way businesses manage and process consumers’ personal data. Much like the GDPR, the CCPA will reach beyond California’s borders. A company does not need to be incorporated in California to be subject to the CCPA. The CCPA applies to companies that “do business in the State of California” and meet certain other threshold requirements. The statute does not define “does business.”
While Congress and other state legislatures have not yet adopted such impactful data privacy laws, experts anticipate that the CCPA will usher in a wave of privacy law developments across the U.S. The New York Senate currently is considering the New York Privacy Act (NYPA). The bill stretches further than California’s law, because it would apply to nonprofits and impose fiduciary duties on businesses holding consumer data.
Whether it is the CCPA, the NYPA or other future privacy laws, blockchain organizations need to comply with these rapidly evolving data privacy laws.
Employment and Labor Law
Employment and labor law issues abound in the blockchain space.
New entrepreneurs might not appreciate the panoply of mandatory employee benefits. For example, New York City Local Law No. 96 requires employers with 15 or more employees to conduct annual anti-sexual harassment training for all employees. By October 2019, New York will require all employers to create yearly anti-sexual harassment training programs and conduct their first training.
As of January 2019, employers in New York must provide employees at least 10 weeks of paid family leave. Though technology companies usually offer lifestyle benefits in order to stay competitive, they need to specifically comply with these new laws. Even though startups may lack the capital to provide extensive benefits, that is no defense against meeting the minimum requirements.
Similarly, technology companies often lack the capital resources to hire large salaried staffs in their early days. Instead, they hire independent contractors. However, if independent contractors receive a certain level of direction and act in accordance with that direction, courts could find them to be employees. Companies would then be liable for payroll taxes and other benefits of their so-called independent contractors.
Compensation structures vary as well, with start-ups often offering employees equity in the new company. This structure might be ideal for companies with little working capital that want to incentivize their employees to help the company succeed. However, depending on state labor laws, such compensation schemes might be inadequate. Even significant equity compensation might not satisfy salary, minimum wage or overtime requirements. Employees might be entitled to traditional forms of compensation as well.
Additionally, minimum wage requirements are constantly on the rise. In New York City, “big employers,” those with 11 or more employees, saw a minimum wage increase from $13 an hour in 2017 to $15 in 2018. “Small employers,” with 10 or fewer employees, saw the $15 jump at the start of 2019. These numbers are expected to rise.
Labor law violations could result in employee lawsuits, Department of Labor audits and fines. Under federal law, salaried employees can receive only up to 10 percent of their payment in nondiscretionary bonuses, incentives and commissions. Though “business owners” under federal law are exempt from salary regulations, business owners are only those with at least a 20 percent equity interest in the company who actively manage the company.
Blockchain businesses need counsel familiar with compensation packages that meet start-ups’ goals while still complying with federal, state and local labor laws.
One major criticism of the government’s regulation of blockchain technology is that it will stymie innovative development and broad use of the technology in various business fields and deter people from entering the industry. It will also scare away entrepreneurs and investment capital that otherwise would contribute to growing the industry.
But with the assistance of experienced and knowledgeable outside general counsel in areas of law pertinent to blockchain, innovators can build legally compliant businesses with confidence.
* Marc D. Powers is a senior partner in BakerHostetler’s New York office and acting as outside general counsel for blockchain industry companies; he formerly was the national leader of the law firm’s Hedge Fund Industry and Securities Litigation & Regulatory Enforcement practices and a SEC enforcement division branch chief. Co-author Madison Gaudreau is a law student of at Fordham University School of Law and was an associate of at the law firm BakerHostetler this past summer. The views expressed in this article are those of the authors and not necessarily those of BakerHostetler or its clients.
 See generally SEC v. Aqua-Sonic Prod. Corp., 687 F.2d 577 (2d Cir. 1982).
 Brian Penny, What Is the Kin Ecosystem? Introduction to Kik’s KIN Token, Crypto Briefing (Feb. 10, 2019), https://cryptobriefing.com/what-is-the-kin-ecosystem-introduction-to-kiks-kin-token/.
 Id. Kinit is a Kin marketplace app. See id.
 Founding Members, Libra Association, https://libra.org/en-US/association/#founding_members (2019).
 White Paper, Libra Association, https://libra.org/en-US/white-paper/#introducing-libra (2019) (“[Libra] is governed by the independent Libra Association tasked with evolving the ecosystem.”).
 Our Mission, Tezos Foundation, https://tezos.foundation/about (2019).
 See Ethereum Foundation Spring 2019 Update, Ethereum Blog (May 21, 2019), https://blog.ethereum.org/2019/05/21/ethereum-foundation-spring-2019-update/.
 Joresa Blout, 10 Blockchain Companies to Watch in 2019, Forbes (May 31, 2019), https://www.forbes.com/sites/joresablount/2019/05/31/10-blockchain-companies-to-watch-in-2019/#2c69b7dc543f.
 William Mougayar, Is the Window Closing on US Blockchain Leadership, CoinDesk (Jan. 7, 2019), https://www.coindesk.com/is-the-window-closing-on-us-blockchain-leadership.
 Brenna Hughes Neghaiwi, Switzerland Tries to Stem Blockchain Exodus by Improving Access to Banks, Reuters (Sept. 21, 2018), https://www.reuters.com/article/us-crypto-currencies-switzerland/switzerland-tries-to-stem-blockchain-exodus-by-improving-access-to-banks-idUSKCN1M11H3.
 Supra, note 2.
 Bloomberg: Crypto Companies Still Run into Trouble Opening Bank Accounts, Blockchain Bitcoin Info (Mar. 3, 2019), https://superblockchainbitcoin.com/2019/03/03/bloomberg-crypto-companies-still-run-into-trouble-opening-bank-accounts/.
 Shalin Soni, Blockchain Companies Now Can Easily Access Corporate Bank Accounts in Switzerland, Crypton (Sept. 22, 2018), https://www.cryptonewsz.com/blockchain-companies-now-can-easily-access-corporate-bank-accounts-in-switzerland/1382/.
 15 U.S.C. 77b(1).
 31 CFR 1010.100(ff).
 SEC, Strategic Hub for Innovation & Fin. Tech., Framework for “Investment Contract” Analysis of Digital Assets (2019).
 328 U.S. 293 (1946).
 Supra, note 27.
 Report of Investigation pursuant to Section 21(a) of the Securities Exchange Act of 1934: The DAO (Exchange Act Rel. No. 81207) (July 25, 2017) https://www.sec.gov/litigation/investreport/3-81207.pdf.
 Philip Rosenstein, SEC’s Peirce Concerned Over Lack of Crypto Guidance, Law360 (May 9, 2019), https://www.law360.com/articles/1158263/sec-s-peirce-concerned-over-lack-of-crypto-guidance.
 Nikhilesh De, The SEC Is Suing Kik for Its 2017 ICO, CoinDesk (June 4, 2019), https://www.coindesk.com/the-sec-is-suing-kik-for-its-2017-ico.
 Regulation D Offerings, SEC, https://www.sec.gov/fast-answers/answers-regdhtm.html (last updated Nov. 27, 2017).
 See generally 17 C.F.R. § 230.501(a) (2016).
 Rule 506 of Regulation D, SEC, https://www.sec.gov/fast-answers/answers-rule506htm.html (last updated Nov. 27, 2017).
 Paul Vigna, SEC Clears Blockstack to Hold First Regulated Token Offering, Wall St. J. (July 10, 2019), https://www.wsj.com/articles/sec-clears-blockstack-to-hold-first-regulated-token-offering-11562794848?mod=searchresults&page=1&pos=3.
 Daniel Kuhn, SEC Gives YouNow’s Ethereum Token ‘Props’ Reg A+ Approval, CoinDesk (July 11, 2019), https://www.coindesk.com/sec-gives-younows-ethereum-token-props-reg-a-approval.
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 See 566 U.S. 66 (2012).
 Inayat Chaudhry, The Patentability of Blockchain Technology and the Future of Innovation, Landslide (Mar. 2018), https://www.americanbar.org/groups/intellectual_property_law/publications/landslide/2017-18/march-april/patentability-blockchain-technology-future-innovation/#12.
 Neil Chilson, It’s Time for a FTC Blockchain Working Group, [email protected] (Mar. 16, 2018), https://www.ftc.gov/news-events/blogs/techftc/2018/03/its-time-ftc-blockchain-working-group.
 See id.
 Lauren Gilmore, 7 Interesting Laws Blockchain Will Force to Change, The Next Web (May 15, 2017), https://thenextweb.com/reinvent-the-future-of-finance/2017/05/15/7-interesting-laws-blockchain-apps-will-force-to-change/.
 Aaron Schildhaus, EU’s General Data Protection Regulation (GDPR): Key Provisions and Best Practices, Int’l L. News (June 5, 2019), https://www.americanbar.org/groups/international_law/publications/international_law_news/2018/winter/eu-general-data-protection-regulation-gdpr/.
 See Cal. Civ. Code § 1798.140(c)(1) (2018).
 Issie Lapowsky, New York’s Privacy Bill Is Even Bolder Than California’s, Wired (June 4, 2019), https://www.wired.com/story/new-york-privacy-act-bolder/.
 N.Y.C., N.Y., Admin. Code § 8-107 30(b) (2018).
 Lisa Nagele-Piazza, New York Employers Must Provide Sexual-Harassment Training, SHRM (Apr. 27, 2018), https://www.shrm.org/ResourcesAndTools/legal-and-compliance/state-and-local-updates/Pages/New-York-Sexual-Harassment-Training.aspx.
 Paid Family Leave, N.Y. State, https://paidfamilyleave.ny.gov/2019 (last visited June 17, 2019).
 New York State’s Minimum Wage, N.Y. State, https://www.ny.gov/new-york-states-minimum-wage/new-york-states-minimum-wage (last visited June 17, 2019).
 See 29 C.F.R. § 541.602(a)(3).
 See 29 C.F.R. § 541.101.
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