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Separate CAS Noncompliances May Get Separate SOL

Client Alert | 1 min read | 01.22.14

In Appeal of Fluor Corp., the ASBCA held that the government's claim relating to an alleged CAS 403 noncompliance "was a continuing claim inherently susceptible to being broken down into a series of independent distinct events," namely, each payment by the government for a CAS-non-compliant billing. Thus, the board held that, under the CDA's statute of limitations, the government "knew or should have known" that it had a claim against the contractor as of the date the compliance audit was completed (for amounts paid before that date), but that claims for the same alleged CAS noncompliance in subsequent years would not accrue until the amounts at issue for those years had been billed and paid, a result that may save some government claims from the CDA's 6-year SOL (previously discussed here, here, here, here, and here).


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Client Alert | 5 min read | 10.08.25

California’s AI Transparency Act (CAITA) May be Amended to Regulate Social Media Platforms

Last year, the California General Assembly passed the California AI Transparency Act (CAITA), which Governor Gavin Newsom signed into law on September 19, 2024, and goes into effect on January 1, 2026. This may change because this year, the same General Assembly passed AB 853, an amendment to CAITA with potentially far-reaching implications....