Message from the Chair
Greetings everyone, and welcome to the Litigation
Committee’s fourth quarter newsletter! As this is my first newsletter as the incoming Chair of the Litigation
Committee for the 2017-2018 term, I am excited to share the Committee’s goals
for this coming year. First, I hope everyone had a wonderful Thanksgiving
While our past-Chair Bryon Koepke has
moved on to bigger roles with the ACC, he has left the Committee with a great
outlook for the coming year. Every year, the Committee evaluates its
leadership team and makes adjustments as needed to ensure that the team is
properly staffed and aligned to support the needs of the Committee and all of
its members in the best manner possible. And every year, the leadership team
delivers great programs and resources for our members. This year we added
roles so that there are co-chairs for each subcommittee. Our Executive
Council works hard all year in their respective roles, but we recognize that team
work and backing each other up brings us greater success rates.
We have many of our Executive Council
members returning, and some who have stepped off the EC. We thank Murphy
Burke, Sam Shapiro, and Monica Palko for their work and commitment to the
Committee and its members. Our new additions to the team include Sarah
Maguire of BAE Systems (colleague of former Committee Chair, Monica Palko), and
two of my colleagues at Wyndham, Jennifer Constantinou and Carrie Parikh.
Our Vice Chair, Theresa Coetzee, also recruited her friend Doug Kelly of
Marriott Vacations Worldwide to our team. Members can see the Litigation
Committee Leadership Team here - ACC Litigation Committee
For the coming year, this Committee
plans to generate quality programming for our members, which will include
monthly Legal Quick Hits and CLE eligible webcasts and Annual Meeting sessions;
partnering with chapters and other committees for webinars, roundtable discussions
and co-sponsored legal quick hits; and organizing numerous resources that have
been included in the ACC Docket, ACC Docket Briefings, eGroups, the ACC's Blog
(www.inhouseACCess.com), and within the
resources section of the Committee’s homepage. Additionally, we are
looking to increase our publications by producing Top 5s and Top 10s following
our Legal Quick Hits and webcasts.
The Committee will work with its
sponsors, Norton Rose Fulbright and Integreon, to meet these goals. Both sponsors are still fairly new
to the Committee, and we hope to take advantage of their many resources and
ideas to provide new, cutting-edge content to our membership.
The Committee encourages all of its
members to reach out to any of us on the Leadership Team if you have comments,
suggestions, or especially if you would like to publish an article!
Whether providing a 250 word blog-post summarizing an important case or
legal issue affecting an industry or business, or writing a lengthy, researched
article for the Docket, the Litigation Committee is proud to offer our members
the support they need to publish!
ACC members who are not yet members
of the Litigation Committee can join here, and can also join our LinkedIn page here.
Finally, the Committee continues our commitment to public
service as we continue our collaboration with Kids In Need of Defense
(KIND). KIND is the leading organization for the protection of children
who enter the U.S. immigration system alone and strives to ensure that no such
child appears in immigration court without representation. KIND looks to
achieve fundamental fairness through high-quality legal representation and by
advancing the child’s best interests, safety, and well-being.
Unaccompanied children apprehended at the border face deportation proceedings;
the majority must make their claim for protection without a lawyer. The result:
children can be sent back to situations where their well-being, and even their
lives, are in danger. The Litigation Committee supports KIND’s mission
and encourages all of its members to get involved and to serve as pro bono
counsel for a child in need.
Wishing you all a warm and prosperous holiday season and New
Chair, Litigation Committee
[ Return to Top
Annual Meeting 2017 Blog
By Connor Breza
This year, eWhite House Watch had the privilege of attending the Association of Corporate Counsel’s 2017 Annual Meeting in Washington D.C. on October 16th–18th, 2017. Corporate Counsel from around the world flocked to the nation’s capital for what is recognized to be “the world’s largest gathering of in-house counsel.” Beginning on Sunday October 15th, the convention continued into Wednesday the 18th, hosting a plethora of events geared toward educating in-house lawyers on the latest of current legal issues and providing an excellent opportunity to network and broaden attendees’ legal horizons.
One of the more notable programming that captured our cyber/privacy focus was “Rise of the Machines: Can Compliance and Litigation Keep Up”, featuring speakers Khalid Al-Kofahi, Vice President, R&D, of Thomason Reuters; Cynthia Boeh, General Counsel for Other World Computing; Mark Huller, Senior Counsel and General Manager of the Legal-Litigation Department of The Cincinnati Insurance Company; and Martin Tully, Co-Chair of Akerman LLP’s Data Law Practice Group. This event focused on the implications of AI (artificial intelligence) on the legal field including anti-money laundering, anti-fraud, and export-sanctions compliance programs, discussing questions such as: “Will it eventually be considered negligent to not use AI to identify and monitor compliance risks?” as well as other possibilities for AI in litigation.
“Advising a Board of Directors When Your Company is in Distress” was also one program of particular interest. Speakers Suzanne Folsom of United States Steel Corporation, Stephen Plotnick, partner at Carter Ledyard & Milburn LLP and Meritas-Law Firms Worldwide, Jill Schatz, Corporate Secretary and Board Member at CNOC, and Olvin Valentin, General Counsel of Seaborne Airlines discussed in depth the strategies that a board of directors can engage in to help protect companies and the board from incurring liability to shareholders and creditors when their corporation is in distress.
Other notable programs included “General Counsel’s Role in Cybersecurity Preparedness and Legal Liability from Cybersecurity Exposure”, “The Emerging Law and Public Policy of Self-Driving Vehicles”, “The Federal Trade Commission on Unfairness, Deception, and Consumer Privacy Enforcement Actions”, and “Transformational Payment Services: How FinTech and New Payment Regulations are Impacting Transactions in Europe and Around the World”.
The program “Mapping and Leveraging Stakeholders in Litigation Matters”, moderated by Ilona Korzha of Sprint, highlighted the nuance of corporate litigation when there are multiple stakeholders involved. The panel, made up of speakers Wendy Bozzolasco, Senior Litigation Counsel of Sunpower, Robert Daniel, Senior Director of Integreon’s Financial Services Practice Group, Brad DeVore of Womble Carlyle Sandridge & Rice, LLP, and Matthew Fore, VP of Litigation for Hilton, went in to detail on the various methods of neutralizing and leveraging parties, internally and externally, who may have an interest in a corporation’s litigation. The program highlighted ways that utilizing a “stakeholder map” can “help in-house counsel identify and analyze litigation resources, timing and communications.” The ACC described this event as a “must-attend for anyone managing large litigation.”
The ACC holds itself to be “the voice of the in-house bar”, maintaining an international membership of more than 43,000 in-house lawyers at over 10,000 corporations and NGO’s in 85 different countries. This year, the ACC Annual Meeting offered in excess of 100 CLE/CPD sessions, including greater than 30 hours of networking for the more than 2,500 professionals in attendance from over 35 countries. Founded in 1982, the ACC now has a prominent presence worldwide with 59 chapters spanning almost every continent across the globe.
As President and CEO of the organization, Veta T. Richardson’s top priority is to “increase ACC’s global footprint and leading the organization through a strategic plan and vision designed to strengthen its position as the global voice for in-house counsel.” Ms. Richardson’s most recent accomplishment as CEO was leading “ACC’s membership merger with three national associations and their integration as ACC Middle East (Dubai), ACC Australia and ACC Hong Kong within the 59 chapter network, and increasing ACC’s membership by 10 percent.”
On Tuesday, October 17th the ACC offered several awards to distinguished entities. These included honoring Troy Swan, the head of legal and company secretary at Staples- Australia & New Zealand as member of the year; the Mastercard Law Department with the ACC’s Diversity Award; Exxon Mobil Corporation’s Pro Bono Program with the ACC Corporate Pro Bono Award; among several other awards to the ACC’s various committees. Acknowledging these recipients achievements, Ms. Richardson commented, “Whether through pro bono and diversity initiatives or membership recruitment and innovative programming efforts, this year’s award recipients have played an important role in driving change within the global legal and business community.”
[ Return to Top
Risk of Identity Theft from Cyberattack Constitutes Sufficient Injury to Sustain Lawsuit
By Stephen Stern and Ilona Korza
With cyberattacks seemingly happening with greater frequency, the risk of identity theft for many individuals has grown significantly. However, is the risk of identity theft (as opposed to actually identity theft) after a cyberattack sufficient to sustain a lawsuit for damages? In Attias v. Carefirst, Inc., 865 F.3d 620 (D.C. Cir. 2017), the United States Court of Appeals for the District of Columbia Circuit ruled that the threat of identity theft may be sufficient to establish standing and sustain a lawsuit for damages against the company that was hacked in the cyberattack.
CareFirst and its subsidiaries provide health insurance coverage to approximately one million individuals in the District of Columbia, Maryland, and Virginia. In June 2014, a hacker breached 22 CareFirst computers and accessed a database containing personal information of CareFirst customers, including customer names, addresses, subscriber identification numbers, and social security numbers. CareFirst did not discover the breach until April 2015 and did not disclose it to its customers until May 2015. Seven CareFirst customers filed a class action complaint against CareFirst and its subsidiaries in federal court in the District of Columbia alleging breach of contract, negligence, and violations of various state consumer protection statutes, among other claims. The district court dismissed the lawsuit for lack of standing, finding that the alleged injury – increased risk of identity theft resulting from the data breach – was too speculative. The plaintiffs appealed.
After addressing some procedural issues, the appellate court turned to the question of whether the plaintiffs had alleged a sufficient injury to satisfy the “injury-in-fact” requirement for standing under Article III of the Constitution. To this end, a plaintiff must show that he/she has suffered an “injury-in-fact” that is “fairly traceable” to the defendant’s actions and that is “likely to be redressed” by the relief the plaintiff seeks. After reviewing some prior decisions by the United States Supreme Court, the D.C. Circuit explained that a plaintiff may establish standing by satisfying either the “certainly impending” test or the “substantial risk” test. The court then focused on the “substantial risk” test and cited a number of its previous decisions where it ruled that plaintiffs had alleged a “substantial risk” of future injury sufficient to establish standing. The “proper way to analyze an increased-risk-of-harm claim [in the D.C. Circuit] is to consider the ultimate alleged harm . . . as the concrete and particularized injury and then to determine whether the increased risk of such harm makes injury to an individual citizen sufficiently ‘imminent’ for standing purposes.” The court stated that there is no doubt that identify theft constitutes a concrete and particularized injury, but the question before it was whether the plaintiffs alleged that they faced a substantial risk of identity theft as a result of CareFirst’s alleged negligence in connection with the cyberattack.
The court noted that the plaintiffs had alleged CareFirst collected and stored personal identifying information, including personal health information and other sensitive information such as patient credit card and social security numbers, and this information was accessed during the cyberattack on CareFirst. The plaintiffs further alleged that identity thieves could use the information they obtained from CareFirst to open new financial accounts, incur charges in another person’s name, and commit various other acts of financial misconduct. Other potential harm described in the complaint included “medical identity theft,” which can lead to improper medical care, depletion of insurance, ineligibility of health or life insurance, and disqualification from certain jobs. Based on these and other related allegations, the court found that the complaint “plausibly alleges that the CareFirst data breach exposed customers’ social security and credit card numbers.” The court further noted that, based on “experience and common sense,” the plaintiffs “face a substantial risk of identity theft if their social security numbers and credit card numbers were accessed by a network intruder.” Citing to a decision by the United States Court of Appeals for the Seventh Circuit, the court further found that the risk of harm was substantial in that “[w]hy else would hackers break into a . . . database and steal consumers’ private information? Presumably, the purpose of the hack is, sooner or later, to make fraudulent charges or assume those consumers’ identities.”
The court then noted that simply alleging an injury alone is not enough to establish standing; the plaintiffs must allege a “fairly traceable [injury] to the challenged conduct of the defendant.” CareFirst argued that the plaintiffs’ injuries were “fairly traceable” only to the identity thieves, which the court acknowledged was somewhat correct and that CareFirst’s failure to secure its customers’ data was one step removed from the causal chain. The D.C. Circuit explained, however, that “Article III standing does not require that the defendant be the most immediate cause, or even a proximate cause, of the plaintiffs’ injuries; it requires only that those injuries be ‘fairly traceable’ to the defendant.” The court then “assume[d], for purposes of the standing analysis, that [the] plaintiffs will prevail on the merits of their claim that CareFirst failed to properly secure their data and thereby subjected them to a substantial risk of identity theft . . . [and, thus, it had] little difficulty concluding that [the plaintiffs’] injury in fact is fairly traceable to CareFirst.”
Lastly, the court found that the plaintiffs satisfied the last element for standing, which is that their injury must likely be redressed with a favorable decision by the court. To this end, the plaintiffs alleged that they had incurred costs to mitigate or avoid the harm of identity theft, such as identity theft protection and monitoring and conducting damage assessments. Thus, the plaintiffs could potentially recoup monetary damages.
With increasing reports of cyberattacks, including the recent report of such an attack on Experian, we are likely to see more and more lawsuits filed against companies that have been hacked. The decision in Attias illustrates how such claims can survive early dismissal from challenges to Article III standing. Companies face substantial exposure to these claims and, thus, should be taking appropriate technological, insurance, and legal precautions to prevent and mitigate against these risks.
[ Return to Top
Circuit Split Over Standing in Data Breach Litigation Continues
By Stephen Stern and Ilona Korza
With cyberattacks on the rise, so is data breach litigation initiated by plaintiffs who claim that they have been harmed by the exposure of their personal information. As a result, more and more courts are confronting the threshold issue of standing under Article III of the Constitution for these plaintiffs, and they are coming to different conclusions.
The United States Court of Appeals for the Eighth Circuit is the latest federal appellate court to rule in a case involving Article III standing for data breach litigation. In In re SuperValu, Inc., 870 F.3d 763 (8th Cir. 2017), the Eighth Circuit held that fifteen out of sixteen plaintiffs failed to allege they had suffered identify theft and/or incurred fraudulent charges and, thus, they did not meet the Constitutional requirements for standing. The Eighth Circuit concluded that the alleged risk of some future harm was not sufficient to satisfy the standing requirements to bring a lawsuit.
SuperValu, the defendant in this case, owned and operated grocery stores across the United States. In 2014, SuperValu suffered two cyberattacks in which “[t]he hackers installed malicious software on defendants’ network that allowed them to gain access to the payment card information of defendants’ customers (hereinafter, Card Information), including their names, credit or debit card account numbers, expiration dates, card verification value (CVV) codes, and personal identification numbers (PINs).”In both instances, SuperValu issued a press release acknowledging the cyberattack and the potential theft of some customers’ Card Information, but there was no determination as to whether “such information ‘was in fact stolen.’” Following the data breach, customers who shopped at the affected SuperValu stores had to determine if their cards were compromised. They spent time reviewing the information released about the breaches and the impacted locations, and monitored account information to guard against potential fraud. Only one of the plaintiffs, however, David Holmes (“Holmes”), specifically noticed a fraudulent charge on his credit card statement following the breach. He immediately cancelled his credit card, and waited two weeks to receive a replacement card.
The customers allegedly affected by the data breach brought numerous class actions, which were later consolidated in the United States District Court for the District of Minnesota. The complaint alleged violations of state consumer protection statutes and state data breach notification statutes, negligence (including negligence per se), breach of implied contract, and unjust enrichment. SuperValu moved to dismiss the complaint, and the district court granted dismissal under Federal Rule of Civil Procedure 12(b)(1). According to the district court’s findings, all of the plaintiffs had failed to allege an injury-in-fact and, thus, they lacked standing to bring a suit. The plaintiffs appealed the court’s dismissal and the defendants cross appealed, arguing for dismissal with prejudice under Rule 12(b)(6).
On appeal, the plaintiffs took the position that the complaint “sufficiently alleged an injury in fact because the theft of their Card Information in the data breaches at defendants’ store created a substantial risk that they will suffer identity theft in the future.” They alleged “on information and belief, [that] illicit websites [were] selling their Card Information to counterfeiters and fraudsters, and that plaintiffs’ financial institutions [were] attempting to mitigate their risk.” Only one of the plaintiffs, Holmes, alleged the “actual misuse of his Card Information” as a result of the data breaches – a present injury, which he specifically argued was “causally connected to defendants’ careless security practices.”
Relying on prior cases decided by the United States Supreme Court (Clapper v. Amnesty Int’l USA, 568 U.S. 398 (2013), and Susan B. Anthony List v. Driehaus, ___ U.S. ___, 134 S. Ct. 2334 (2014)), the Eighth Circuit explained that future harm can be sufficient to establish Article III standing only if plaintiffs can “demonstrate that ‘the threatened injury is certainly impending, or there is a substantial risk that harm will occur.” (emphasis added). The Eighth Circuit was tasked with “determin[ing] whether plaintiffs’ allegations plausibly demonstrate[d] that the risk that plaintiffs [would] suffer future identity theft [was] substantial.” In support of their position that the threat of future identity theft was certainly pending or substantial, the plaintiffs relied on a 2007 Government Accountability Office (“GAO”) report. The Eighth Circuit found the GAO report unpersuasive because, even though the report acknowledged some data breach incidents could result in identity theft, “it conclude[d] based on the ‘available data and information’ that ‘most breaches have not in fact resulted in detected incidents of identity theft.” The court further noted the possibility that in some years, “more detailed factual support for plaintiffs’ allegations of future injury” may become available, but the complaint, as it stood, alleged a “mere possibility,” which was insufficient for standing. The Eighth Circuit also rejected the plaintiffs’ argument that the time spent and the costs incurred to “mitigate their risk of identity theft [by] reviewing information about the breach and monitoring their account information” amounted to an injury in fact. Because plaintiffs had failed to allege a substantial risk of future identity theft, the court concluded that the costs incurred by the plaintiffs were to protect against a “speculative threat[,]” and did not create an injury for standing purposes. (emphasis added).
The Eighth Circuit, however, found that Holmes met the threshold requirement for Article III standing by alleging the actual “misuse of his Card Information.” The court concluded that the complaint, as it related to Holmes, “contained sufficient allegations to show that [he] suffered an injury in fact, fairly traceable to defendants’ security practices, and likely to be redressed by a favorable judgment [and, thus,] Holmes had standing under Article III’s case or controversy requirement.”
The Eighth Circuit acknowledged that other courts, such as the United States Court of Appeals for the District of Columbia Circuit and the United States Court of Appeals for the Seventh Circuit, had reached different conclusions on standing for data breach litigation. In those cases, the courts found it plausible to infer that hackers stole consumers’ private information with the intent to make fraudulent charges or steal their identities and, thus, the data breach had created a substantial risk of harm to those plaintiffs because their personal information had been exposed. The Eighth Circuit, however, followed the analysis of the United States Court of Appeals for the Fourth Circuit (Beck v. McDonald, 848 F.3d 262 (4th Cir. 2017)), and declined to make such an inferential step that a breach would result in future harm. In Beck, the Fourth Circuit explained even if the statistics relied upon by plaintiffs were true, which purported to show that 33% of individuals impacted in the data breach would suffer identity theft, it necessarily followed that 66% would not suffer such harm, which was insufficient to establish a substantial risk of harm necessary for Article III standing.
As cyberattacks increase and more plaintiffs initiate data breach litigation, courts will continue to grapple with these different positions on what data breach plaintiffs must allege to establish a substantial risk of future harm. In the meantime, however, the Eighth Circuit’s holding in In re SuperValu shows that courts are not moving uniformly on the issue of Article III standing as it relates to data breach litigation and, as a result, some circuits are more plaintiff friendly while others are not.
[ Return to Top
Personal Jurisdiction Defense Gaining Traction in Mass Tort Litigation
By Kevin J. Penhallegon at Miles Stockbridge
For the past several years, the U.S. Supreme Court has sought to clarify the proper exercise of specific personal jurisdiction over foreign corporate defendants. This issue is particularly applicable in mass tort litigation where out-of-state plaintiffs are often grouped together with in-state plaintiffs for a consolidated trial setting. The Supreme Court addressed that concern in the groundbreaking decision Bristol-Myers Squibb Co. v. Superior Court of California, 137 S. Ct. 1773 (2017) (discussed here). In Bristol-Myers, the Supreme Court ultimately held that state courts could not circumvent the constitutional requirements for specific jurisdiction without the plaintiff(s) (resident or non-resident) proving a connection between alleged injuries and the corporate defendant’s activities in the forum state. It was anticipated that Bristol-Myers would have immediate and significant impacts nationwide. These impacts are now being seen at the state level, as evidenced by several recent decisions, including Estate of Fox v. Johnson & Johnson, No. ED104580 (Mo. Ct. App. Oct. 17, 2017).
In Fox, Ms. Fox was one of 65 individual plaintiffs who alleged that she developed ovarian cancer as a result of using talcum powder sold by Johnson & Johnson. Two of the 65 individual plaintiffs were Missouri residents, while the other 63 individual plaintiffs, including Ms. Fox, bought and used the products in other states. The non-resident plaintiffs joined their claims to the Missouri resident plaintiffs’ claims pursuant to Missouri Rule 52.05. The defendants filed a motion to dismiss the claims of the non-resident plaintiffs for lack of personal jurisdiction. The trial court denied the motion on the basis that each non-resident need not establish an individual basis for jurisdiction, so long as a defendant has sufficient minimum contacts with the state. In this case, the trial court found that the defendants’ commercial activity in Missouri “more than adequately” satisfied minimum contacts. Following a jury verdict for the plaintiffs, on appeal, both parties agreed that Bristol-Myers was controlling, but disagreed as to the resulting outcome. The plaintiffs sought a remand to the trial court for further factual development on the issue of personal jurisdiction, while the defendants asked the appellate court for an outright dismissal with prejudice. The Missouri Court of Appeals declined to remand the case and reversed and vacated the trial court’s judgment for lack of personal jurisdiction.
In contrast, a recent trial court opinion in a hernia mesh multi-district litigation case (MDL) in New Hampshire, In re Atrium Med. Corp. C-Qur Mesh Prods. Liab. Litig., allowed for further jurisdictional discovery to determine whether the court has personal jurisdiction over a holding company based in Sweden. No. 16-md-2753 LM, 2017 WL 5514193 (D.N.H. Nov. 14, 2017). In that case, the Swedish company did not make or sell the products in question, and it was undisputed that the company had no direct contacts with the United States. The plaintiffs raised several arguments in opposition to the Swedish company’s motion to dismiss: the Swedish company waived its personal jurisdiction defense by participating in the MDL; the Swedish company was judicially estopped from asserting a personal jurisdiction defense because it had previously participated in litigation in the jurisdiction; and the other defendants’ forum contacts could be attributed to the Swedish company. The court appeared to reject some of the arguments but allowed additional limited discovery before deciding whether the Swedish company would prevail on its personal jurisdiction defense.
The Missouri Court of Appeals’ decision in Fox and the plaintiff’s arguments in the hernia mesh MDL in New Hampshire exemplify the significant impact that a personal jurisdiction analysis can have on mass tort litigation, particularly in jurisdictions where out-of-state plaintiffs routinely join actions with in-state plaintiffs. Significantly, and as explained by Judge Odenwald in a concurring opinion in Fox, the court lacked authority to remand for further factual development because Bristol-Myers did not present new law but rather clarified the long-established principles of personal jurisdiction established in prior precedents, including Int’l Shoe Co. v. Washington, 326 U.S. 310 (1945), and Daimler AG v. Bauman, 134 S. Ct. 746 (2014). In fact, Judge Odenwald pointed to the fact that Bauman clearly established the governing principles and was decided months before the plaintiff filed her case in Missouri state court. The Fox decision will likely have an impact at the trial court level where courts will be more cognizant of the Supreme Court’s prior precedent and the rationale underlying the establishment of personal jurisdiction. This may lead to trial courts allowing for “jurisdictional discovery,” as was done in the hernia mesh MDL, to develop a substantial factual record on which to make the decision.
Disclaimer: This is for general information and is not intended to be and should not be taken as legal advice for any particular matter. It is not intended to and does not create any attorney-client relationship. The opinions expressed and any legal positions asserted in the article are those of the author and do not necessarily reflect the opinions or positions of Miles & Stockbridge, its other lawyers or the ACC Litigation Newsletter.
[ Return to Top
Meet Deanna Kwong!
What are your general responsibilities in your current role?
I am IP Litigation Counsel at Hewlett Packard Enterprise Company. Our IP Litigation team is responsible for managing all IP lawsuits that are filed against or by HPE in the U.S., and supporting all IP disputes worldwide. We also provide general IP Litigation-related advice to our businesses. We handle certain matters solely in-house, and manage outside counsel teams on other larger, often more complex matters.
What is your favorite part of your job? Least favorite?
I most enjoy the strategic decision-making associated with litigation and, when our cases do make their way to trial, still love trying jury cases. One of the least favorite aspects of my job is reviewing invoices from outside counsel – not sure if it is more painful for me to remind teams to submit them on time and then for me to review them, or for outside counsel to prepare the invoices in the first instance!
When you are not at work, what are some of your hobbies or interests?
I love running and training for marathons and ultramarathons. I will be running Boston in April for the first time, and hope to complete my first 50-miler race in 2018 as well.
[ Return to Top