Beverage Legislation | Read Time: < 1 minute

Florida Beverage Legislation: 2022 Pre-Session Review of Beverage Bills

The 2022 Session of the Florida Legislature will include consideration of a number of bills affecting breweries, wineries, distilleries, retailers and consumers. The 2022 regular session of the Florida Legislature kicks off Tuesday, January 11, 2022. This 2-month session will see the consideration of a number of bills that could affect the Florida beverage industry as soon as July. For a refresher on how a bill goes from being introduced to becoming law in Florida, check out the Florida Senate’s Idea-to-Law Flowchart and the Florida League of City’s short video: Florida’s Legislative Process 101. The following chart provides a summary of this session’s beverage-focused bills. We’ll check back in on the status of these bills at end of the session. Do you have any questions about how these proposed changes to Florida Beverage Laws could affect your beverage business? Contact us at contact@brewerlong.com to schedule a consultation with a beverage attorney. Because we’re attorneys: Disclaimer.

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Beverage Legislation | Read Time: 3 minutes

Grains of Paradise, and What They Mean for Florida’s Alcohol Adulteration Statute

Florida’s 150 Year Old Alcohol Adulteration Statute The Florida Beverage Law is, in many instances, confusing, contradictory, and just plain weird. It is also unenforceable in some aspects. Take for instance Florida’s Adulterated Liquor Statute, Florida Statutes Section 562.455. First enacted in 1868, the relatively short Adulterated Liquor Statute makes it a felony of the third degree to include certain substances in alcohol. Whoever adulterates, for the purpose of sale, any liquor, used or intended for drink, with cocculus indicus, vitriol, opium, alum, capsicum, copperas, laurel water, logwood, brazil wood, cochineal, sugar of lead, or any other substance which is poisonous or injurious to health, and whoever knowingly sells any liquor so adulterated, commits a felony of the third degree, punishable as provided in s. 775.082, s. 775.083, or s. 775.084. Florida Statutes Section 562.455 (2021) Chances are, this statute is unenforceable in some respects. That was the conclusion of a federal court in 2020, and it got one “adulterator” taken off the list. The Case of the Aframomum Melegueta Prior to July 1, 2021, the verboten list of alcohol adulterators included one more: grains of paradise. Grains of paradise (scientific name Aframomum melegueta) is a species in the ginger family, closely related to cardamom. Its seeds are used as a spice (ground or whole); it imparts a pungent, black-pepper-like flavor with hints of citrus. It is also common known as melegueta pepper. Florida Law 2021-135 removed grains of paradise from Florida’s Adulterated Liquor Statute because a federal court found the law to be unenforceable, at least where grains of paradise are concerned. On January 28, 2020, the United States District Court for the Southern District of Florida held that the statute, specifically as it related to the use of grains of paradise in liquor, was preempted by federal law. The court found that the statute frustrated the purposes and objectives of the Federal Food, Drug and Cosmetic Act (FFDCA) and implementation of FDA regulations. Under FFDCA, the FDA has broad regulatory authority to monitor and control the introduction of “food additives” in interstate commerce. Florida’s Adulterated Liquor Statute was unenforceable because it prohibited the use of an additive that is generally regarded as safe by the FDA (referred to as GRAS). Source: Bill Analysis for Florida Senate Bill 1966 (2021). Will More “Adulterators” be Removed? What about the rest of the Florida statute’s list of alcohol adulterators? It seems likely that federal preemption applies to other entries on this list, particularly those that are general regarded as safe by the FDA (we’re looking at you, capsicum). Following is Florida’s list of the remaining substances forbidden to be included in alcohol: Cocculus indicus – known as moonseed; historically used to enhance giddiness Vitriol – probably referring to ether, which is also known as “sweet oil of vitriol” Opium – narcotic Alum – used  as a flocculant to clarify turbid liquids and as a dye Capsicum – pepper plants; Capsicum frutescens L. (includes Tabasco pepper) and Capsicum annuum L. (includes bell, jalapenos, chili, and cayenne peppers) are GRAS Copperas – iron sulfate; used in iron supplements and as a dye Laurel Water – distilled from cherry laurel leaves; contains prussaic acid Logwood – probably referring to brushhollies or xylosmas; used as a dye; has narcotic properties Brazil Wood – also known as Pernambuco wood; used as a dye Cochineal – a parasitic insect; used to produce carmine (red) dye Sugar of Lead – lead acetate; has a sweet taste, which led to its historical use as a sugar substitute in wines and foods Do you have any questions about Florida’s Alcohol Adulteration Statute? Contact us at contact@brewerlong.com to schedule a consultation with a beverage attorney. Because we’re attorneys: Disclaimer.

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ABT | Read Time: 5 minutes

2021 Florida Craft Distilleries Law: 5 Unanswered Questions

We reviewed the 2021 Florida Craft Distilleries Law in two prior blog posts–2021 Florida Craft Distilleries Law: General Overview and 2021 Florida Craft Distilleries Law: Destination Entertainment Venues–but questions remain. Following are just five questions we have about the new law. Question #1: Can new Florida craft distillery apply directly for the DD(CD) license? It is unclear whether a new craft distillery must first obtain a Florida distillery (DD) license and only then can request designation as a craft distillery (DD(CD)). Concerning licensing of a craft distillery, the 2021 Florida Distilleries Law added the following statutory provision: A distillery may not operate as a craft distillery until the distillery has provided to the [Florida Division of Alcoholic Beverages and Tobacco] written notification that it meets the criteria specified in paragraph (1)(b). Upon the division’s receipt of the notification and its verification that the distillery meets all such criteria, the division shall add the designation of craft distiller on the distillery’s license. Fla. Stat. S. 565.03(2)(a) (2021) The answer to this question is worth $3,000. That is, the annual license fee for a DD license is $4,000, whereas the annual license fee for a DD(CD) license is $1,000. Will the ABT require a new applicant to first pay $4,000 to obtain a DD license before requesting the “craft distillery” designation, or will the ABT allow an applicant to provide the craft distillery written notification at the time of application and pay only $1,000? Question #2: Can Florida breweries with a craft distillery license sell distilled products from their taproom? The 2021 Florida Craft Distilleries Law has already generated strong interest among licensed breweries and wineries wanting to also manufacture and sell distilled products. Nearly all Florida breweries and wineries have an adjoining taproom or tasting room with a vendor license–most often, a 2COP (beer and wine, consumption on premises or carryout) license. Now that Florida craft distilleries are authorized to sell their own distilled products, for consumption on premises, from a “gift shop or tasting room” attached to the distillery, can that be the same space as the brewery taproom or winery tasting room? Where the brewery taproom or winery tasting room has the 2COP license, the answer is probably no–at least until the ABT says otherwise. The premises of a license–the physical space covered by a license–is significant under the Florida Beverage Law. It is unlawful to sell particular alcoholic beverages–whether beer, wine, or distilled spirits– except on the premises covered by the license. See Fla. Stat. S. 562.02. Generally, one licensed premises cannot overlap another licensed premises. The 2021 Florida Craft Distilleries Law authorizes retail sales of distilled spirits as part of the DD(CD) manufacturing license itself, meaning that the distillery’s gift shop/tasting room must be part of the licensed distillery itself. That is, a craft distillery that is attached to a Florida brewery should be permitted to make sales from its owned tasting room that is covered by the craft distillery license, but probably not from a 2COP licensed taproom attached to the brewery. However, the Florida Beverage Law supports at least two exceptions. First, a brewery or winery with a craft distillery, that also has a 4COP (beer, wine, and liquor) licensed taproom or tasting room, should be able to transfer its own distilled products to the 4COP licensed premises for sale under that license. Nothing prohibits a brewery’s taproom having a 4COP quota license or a 4COP-SFS restaurant license. Second, Florida law does allow “special low proof products”, however derived, distilled, mixed, or fermented and which contain less than 6 percent alcohol by volume, to be sold by 2COP licensed vendors. See Fla. Stat. S. 564.06(5)(b). However, the ABT’s existing rule concerning these special low proof products is much more restrictive, limiting the definition of special low proof products to “products sealed by the manufacturer and offered for sale to vendors through licensed distributors in the originally sealed containers.” FAC Rule 61A-3.050. Particularly in light of the 2021 Florida Craft Distilleries Law, this rule may require modification. Question #3: How does a craft distillery obtain a permit to regularly participate in farmers markets? Under the 2021 Florida Craft Distilleries Law, craft distilleries may providing tastings and sales at organized, including farmers markets. The entire statutory provision is here: Craft distilleries may conduct tastings and sales of distilled spirits produced by the craft distilleries at Florida fairs, trade shows, farmers markets, expositions, and festivals. The division shall issue permits to craft distilleries for such tastings and sales. A craft distillery must pay all entry fees and must have a distillery representative present during the event. The permit is limited to the duration and physical location of the event Fla. Stat. 565.17(2) (2021). How will craft distilleries apply for the required permit? Will one permit allow a craft distillery to participate in the same farmers market every week, or will separate permits be required? What will be the cost of each permit? The ABT will have to provide answers to these questions. Question #4: How will Florida craft distilleries comply with the Florida agricultural products requirement? Effective July 1, 2026, Florida craft distilleries will be required to ensure that a minimum of 60 percent of their total finished branded products are distilled in Florida and contain one or more Florida agricultural products. Our sister website and blog, Groves Law, which focuses on the law of Florida agribusiness, already did a deep-dive into what might constitute “Florida agricultural products” for this purpose, but hopefully additional guidance will be provided by the ABT. In addition to what constitutes “Florida agricultural products”, how will the ABT verify that this requirement is met? What records will the distillery be required to keep? Are “total finished branded products” counted by volume or by package? There are a lot of practical questions that must be answered before this requirement becomes effective? Question #5: How many destination entertainment venues (DEVs) will we see? A large part of the 2021 Florida Craft Distilleries Law is focused on […]

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Beverage Legislation | Read Time: 3 minutes

2021 Florida Craft Distilleries Law: Destination Entertainment Venues

The 2021 Florida Craft Distilleries Law creates a new non-quota, consumption-on-premises only alcoholic beverage license that may be issued to a craft distillery located within a destination entertainment venue. Because the ABT has not yet designated class for this new license, this article refers to this license as a 4COP-DEV. For a general discussion of the 2021 Craft Distilleries Law, see 2021 Craft Distilleries Law: General Overview. Craft Distilleries Can Sell More With a 4COP-DEV License The 4COP-DEV license promises to be an important license for the right situation. It is superior to the craft distillery license in at least one way: The 4COP-DEV allows the license holder to sell alcoholic products manufactured by other manufacturers and acquired through a distributor. By comparison, the craft distillery license limits retail sales to products distilled, rectified or blended on premises only.  In addition, the 4COP-DEV license is a non-quota license, meaning that there is not a limited number of licenses available per county. However, the 2021 Craft Distilleries Law creates a number of specific requirements and qualifications for the 4COP-DEV license. Destination Entertainment Venue, Defined Only craft distilleries located within a “destination entertainment venue” (referred to here as a “DEV”) qualify for the 4COP-DEV license. A DEV is a venue that meets all of the following requirements: The venue is located within a designated community redevelopment area authorized under an adopted community redevelopment plan to support urban redevelopment and economic development. The venue is owned by any person licensed as a craft distillery located within the DEV. The venue is adjacent to and served by multimodal transportation options, including, at a minimum, bicycle and pedestrian trails included on an adopted city or county trails map and mass transit routes established by a city, county, or regional transportation authority. The venue is located within an contiguous area of at least 15 acres that contains (a) at least one indoor event venue with a minimum capacity of 150 people and an onsite kitchen, (b) at least one outdoor event venue with a minimum capacity of 1,000 people which has regularly occurring live entertainment, and (c) one or more licensed craft distilleries sharing identical ownership. More Rules and Requirements In addition to being located within a DEV, craft distilleries that wish to hold a 4COP-DEV must meet the following requirements: The premises covered by the 4COP-DEV license (that is, the area on which retail sales are made) must be part of the craft distillery’s licensed premises, including its gift shop or tasting room. The 4COP-DEV licensed premises cannot be separate from the distillery. No more than three craft distilleries may be licensed as a vendor in the same community redevelopment area. All of those craft distilleries must (a) be located within the same DEV, (b) share identical ownership, and (c) each distill, blend, or rectify at least 50,000 gallons of branded products per calendar year. A craft distillery that holds a 4COP-DEV is subject to the following operational requirements: The craft distillery must operate and open for tours during normal business hours at least 5 days a week. The craft distillery is prohibited from making package sales for off-premises consumption or delivering or shipping alcoholic beverages away from the craft distillery (except to a licensed manufacturer, distributor, or exporter). Alcoholic beverages manufactured by another licensed manufacturer, including branded products manufactured at another craft distillery location sharing identical ownership, must be obtained through a licensed distributor. Do you have questions about the 2021 Florida Craft Distilleries Law? Contact us at contact@brewerlong.com to schedule a consultation. Because we’re attorneys: Disclaimer.

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Beverage Legislation | Read Time: 3 minutes

2021 Florida Craft Distilleries Law: General Overview

The 2021 Florida Craft Distilleries Law changes the legal landscape for all craft distilleries in 3 main areas: (1) what they can make and sell to consumers, (2) where they can sell it, and (3) how big they can get. A fourth aspect of the law–the creation of “destination entertainment venues”–will be explored in a future blog post. Florida Craft Distilleries Can Sell Rectified and Blended Products to Consumers (as Long as They are Mostly From Florida) The Florida Beverage Laws previously allowed craft distilleries to sell to consumers only the products entirely distilled on site. Now, Florida craft distilleries can also sell to consumers the products that are distilled off site (even by another distillery) as long as they are rectified or blended on site. Each craft distillery must keep for 3 years accurate records of all alcoholic beverages received from another manufacturer, broker or importer. Effective as of July 1, 2026, a minimum of 60% of a Florida craft distillery’s total finished branded products must be distilled in Florida and contain one or more Florida agricultural products. This requirement is explored further on our sister website and blog, Groves Law, which focuses on the law of Florida agribusiness. Florida Craft Distilleries’ Can Sell Cocktails in Tasting Rooms and at Events Florida craft distilleries were previously limited to selling only packaged products for consumption off premises, and not more than 6 individual containers of each branded product per person per year. Those limitations are gone under the 2021 Florida Craft Distilleries Law. Now, Florida craft distilleries are authorized–without requiring an alcoholic beverage vendor license–to sell their own branded products directly to consumers by the drink for consumption on the premises or by the package in factory-sealed containers for consumption off the premises. Only branded products distilled, rectified or blended on the distillery premises that is located contiguous to the craft distillery’s souvenir gift shop or tasting room may be sold to consumers. A craft distillery may transfer up to 75,000 gallons per calendar year of its branded products to its on-site gift shop and tasting room. In addition to sales through its gift shop or tasting room, Florida craft distilleries are now permitted to conduct tastings and sales of their branded products at Florida fairs, trade shows, farmers markets, expositions, and festivals. A distillery representative must be present during each event. The ABT is authorized to issue permits to craft distilleries for such tastings and sales. Florida craft distilleries are still prohibited from shipping products to consumers and may sell and delivery products only to consumers in a face-to-fact transaction at the distillery property or permitted event. Florida Craft Distilleries Can Get Much Bigger, But Not Too Big The 2021 Craft Distilleries Law authorize larger distilleries to be designated as “craft distilleries”. Only “craft distilleries” are permitted to sell products directly to consumers (as discussed below). Prior to the new law, the “craft distillery” designation was limited to Florida distilleries that distilled not more than 75,000 gallons per calendar year. Now, each craft distillery can distill, rectify, or blend up to 250,000 gallons of distilled spirits per calendar year. While expanding the size of craft distilleries, the 2021 Florida Craft Distilleries Law also created new rules limiting who can own a craft distillery and how many craft distilleries can have under common ownership. A Florida craft distillery may not have its ownership affiliated with another distillery unless that distillery is owned by an individual or entity that distills, rectifies, or blends no more than 250,000 gallons of distilled spirits per calendar year on each of its premises in Florida and in any other state, territory, or country. The law prohibits the transfer of a craft distillery license, or any ownership interest in such license, to an individual or entity that has a direct or indirect ownership interest in any distillery that distills, rectifies, or blends 250,000 gallons or more per calendar year of distilled spirits under any license issued in Florida or in another state, territory or country. A person may not share common ownership, through direct or indirect financial interest, in more than 10 craft distilleries. Of those 10 craft distilleries, (a) not more than 4 may distill, rectify or blend more than 250,000 gallons per calendar year, and (b) not more than 6 may distill, rectify or blend 50,000 gallons of distilled spirits per calendar year. Do you have questions about the 2021 Florida Craft Distilleries Law? Contact us at contact@brewerlong.com to schedule a consultation. Because we’re attorneys: Disclaimer.

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Beverage Legislation | Read Time: 3 minutes

Compliance with Florida’s Cocktails-to-Go Law

A Short History Cocktails-to-Go in Florida Sale and delivery of vendor-prepared alcoholic beverage drinks–Cocktails-to-Go–will be permanent authorized under the Florida Beverage Law beginning July 1, 2021. Cocktails-to-Go were first introduced in March 2020 as part of Governor DeSantis’ Executive Order 20-71 limiting restaurants’ dine-in service, in response to the COVID pandemic. Introduced as Senate Bill 148 and House Bill 329 during the 2021 Florida Legislative Session, the bills were passed by both houses and signed by the governor on May 13, 2021, becoming Florida Law Chapter 2021-30. Strict Rules for Selling Cocktails-to-Go Subject to a number of conditions, certain restaurants and bars are authorized to sell and deliver alcoholic beverage drinks prepared and sealed by the vendor, as well as manufacture-sealed beer, wine, and liquor, for off-premises consumption (referred to here and elsewhere as “Cocktails-to-Go”). Following is a discussion of those conditions. 1. Only Restaurants are authorized to sell Cocktails-to-Go. Cocktails-to-Go can only be sold restaurants (that is, public food service establishments licensed by the Division of Hotels and Restaurants) that hold either a 4COP quota license or a 4COP-SFS license (also known as an “SRX” license). 2. Cocktails-to-Go must be sealed by the manufacturer or by the restaurant. Authorized restaurants are permitted to sell and deliver both manufacture-sealed beer, wine, and liquor beverages and alcoholic beverage drinks prepared and sealed by the restaurant. Only restaurants with a 4COP quota license are permitted to sell bottles of distilled spirits sealed by a manufacturer. 3. Cocktails-to-Go must be accompanied by the sale of food within the same order. For restaurants with a 4COP quota license, the charge for the sale of food and nonalcoholic beverages must be at least 40% of the total charge for hte order. 4. Cocktails-to-Go cannot be sold after the restaurant ceases preparing food for the day or after midnight, whichever is earlier. 5. There are strict requirements for packaging Cocktails-to-Go. Alcoholic beverages, other than manufacturer-sealed containers, must must be placed in a container securely sealed by the restaurant with an unbroken seal that prevents the beverage from being immediately consumed before removal from the premises. The beverage container must also be placed in a bag or other container and secured in a manner that it is visibly apparent if the container has been subsequently opened, and a dated receipt for the alcoholic beverage and food must be attached to the bag or container. As an example of this packaging requirement, imagine that a restaurant employee pours a margarita into a plastic container with a tight fitting lid, then uses electrical tape around the entire lid. The employee then puts the plastic container into a paper bag and staples the top of the bag closed. The employee then staples a copy of the receipt to the bag. 6. Beer that is filled in a container by the restaurant must comply with the size, labeling, and filling requirements that apply to growlers and similar containers. 7. Cocktails-to-Go, other than manufacturer-sealed containers, must be placed in a locked compartment, a locked trunk, or behind the last upright seat when transported by motor vehicle. 8. It is illegal to allow any person under the age of 21 to deliver alcoholic beverages. An agent or employee of the restaurant is required to verify the age of the delivery person before allowing him or her to take possession of an alcoholic beverage. In other words, check each delivery person’s driver license. Do you have questions about compliance with Florida’s Cocktails-to-Go Law? Contact us at contact@brewerlong.com to schedule a consultation. Because we’re attorneys: This blog post is provided on an “as is” and “as available” basis as of the date of publication. We disclaim any duty to update or correct any information contained in this blog post, including errors, even if we are notified about them. To the fullest extent permitted by law, we disclaim all representations or warranties of any kind, express or implied with respect to the information contained in this blog post, including, but not limited to, warranties of merchantability, fitness for a particular purpose, title, non-infringement, accuracy, completeness, and timeliness. We will not be liable for damages of any kind arising from or in connection with your use of or reliance on this blog post, including, but not limited to, direct, indirect, incidental, consequential, and punitive damages. You agree to use this blog post at your own risk. Regarding your particular circumstances, we recommend that you consult your own legal counsel–hopefully BrewerLong.

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Beverage Legislation | Read Time: 2 minutes

Florida Beverage Legislation: 2021 Post-Session Review of Beverage Bills

The 2021 Session of the Florida Legislature will result in major changes to the Florida Beverage Laws affecting how craft distilleries and restaurants sell alcoholic products. Both houses of the Florida Legislature passed two major bills related to alcoholic beverage sales: SB 46 and SB 148. As of this writing, neither bill has been sent to the Governor, but expectations are that the Governor will sign both bills into law. More complete evaluations of both bills will be coming in the following weeks, but here are brief descriptions. SB 46: Craft Distilleries Finally Get to Sell Drinks Senate Bill 46 (along with its companion, House Bill 737) gives several boosts to Florida’s craft distillery industry, starting with an increase in the production limits required to qualify as a craft distillery, from 75,000 gallons to 250,000 gallons. Effective July 1, 2021, SB 46 would allow each craft distillery to sell up to 75,000 gallons per year of its branded products (whether distilled, rectified or blended) to adult customers at its distillery, in bottles for consumption off premises or in drinks on premises. The “six bottles per person per brand per year” requirement is eliminated. Senate Bill 46 also authorizes certain craft distilleries, located within authorized “destination entertainment venues”, to hold vendor quota licenses that would allow them to sell not only their own branded products but also alcoholic beverage products acquired from distributions. SB 148: Restaurants Can Keep Selling Cocktails to Go Senate Bill 148 (along with its companion, House Bill 329) makes permanent the Governor’s COVID-19 “cocktails-to-go” executive order allowing restaurants to deliver mixed drinks together with food orders. The bill provides directions about how these alcoholic beverage products must be packaged and stored during transportation to customers. The following chart provides a summary of this session’s beverage-focused bills and where they ended at the conclusion of the session. Do you have questions about how these changes to Florida Beverage Law could affect our business or your plans for a new beverage business? Contact us at contact@brewerlong.com to schedule a consultation. Because we’re attorneys: This blog post is provided on an “as is” and “as available” basis as of the date of publication. We disclaim any duty to update or correct any information contained in this blog post, including errors, even if we are notified about them. To the fullest extent permitted by law, we disclaim all representations or warranties of any kind, express or implied with respect to the information contained in this blog post, including, but not limited to, warranties of merchantability, fitness for a particular purpose, title, non-infringement, accuracy, completeness, and timeliness. We will not be liable for damages of any kind arising from or in connection with your use of or reliance on this blog post, including, but not limited to, direct, indirect, incidental, consequential, and punitive damages. You agree to use this blog post at your own risk. Regarding your particular circumstances, we recommend that you consult your own legal counsel–hopefully BrewerLong.

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Beverage Legislation | Read Time: 2 minutes

Florida Beverage Legislation: 2021 Pre-Session Review of Beverage Bills

The 2021 Session of the Florida Legislature will include consideration of a number of bills affecting breweries, wineries, distilleries, retailers and consumers. The 2021 regular session of the Florida Legislature kicks off Tuesday, March 2, 2021. This 2-month session will see the consideration of a number of bills (though not as many as in prior years) that could affect the Florida beverage industry as soon as July. For a refresher on how a bill goes from being introduced to becoming law in Florida, check out the Florida Senate’s Idea-to-Law Flowchart and the Florida League of City’s short video: Florida’s Legislative Process 101. The following chart provides a summary of this session’s beverage-focused bills. We’ll check back in on the status of these bills at end of the session. Do you have questions about how these proposed changes to Florida Beverage Law could affect our business or your plans for a new beverage business? Contact us at contact@brewerlong.com to schedule a consultation. Because we’re attorneys: This blog post is provided on an “as is” and “as available” basis as of the date of publication. We disclaim any duty to update or correct any information contained in this blog post, including errors, even if we are notified about them. To the fullest extent permitted by law, we disclaim all representations or warranties of any kind, express or implied with respect to the information contained in this blog post, including, but not limited to, warranties of merchantability, fitness for a particular purpose, title, non-infringement, accuracy, completeness, and timeliness. We will not be liable for damages of any kind arising from or in connection with your use of or reliance on this blog post, including, but not limited to, direct, indirect, incidental, consequential, and punitive damages. You agree to use this blog post at your own risk. Regarding your particular circumstances, we recommend that you consult your own legal counsel–hopefully BrewerLong.

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