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III.An Examination of State Bar Ethics Committees Opinions onCloud Computing.Some law firms find that the advantages of cloud computing outweigh thedisadvantages. As a result, they have abandoned their traditional data storagesolutions in favor of the Cloud. Because cloud computing places client data on remoteservers outside of the lawyer's direct control, it has given rise to some concernsregarding its acceptability under applicable ethics rules. This has catalyzed a responsefrom nineteen State Bar Associations in the form of Ethics Opinions. 19The opinions universally adopt “reasonable care” as the standard for attorneys lookingto store data in the cloud. Unfortunately, it is ultimately impossible to find substantiveguidelines on what constitutes reasonable care. Even where some guidelines do exist,they vary by jurisdiction. This is likely attributable to the rapidly changing nature oftechnology and the needs of attorneys in that jurisdiction.In order to insure a geographically diverse representation, this paper examines opinionsfrom California, Iowa, New York, Pennsylvania, Massachusetts, and North Carolina.A. California – Reasonable CareThe State Bar of California's Standing Committee on Professional Responsibility andConduct issued an opinion in December of 2010 that "sets forth the general analysis19 To date, the following state’s State Bar Associations have rendered ethics opinions on cloudcomputing: Alabama, Arizona, California, Connecticut, Florida, Iowa, Maine, Massachusetts, NewHampshire, New Jersey, New York, Nevada, North Carolina, Ohio, Oregon, Pennsylvania, Vermont,Virginia and Washington.11

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