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Claim Accrual and the Continuing Claims Doctrine: Board Has Jurisdiction Over Claim Comprised of Separate and Distinct Events that Fell within the CDA’s Six-Year Statute of Limitations Period

Client Alert | 1 min read | 05.03.22

In Lockheed Martin Aeronautics Company, ASBCA No. 62209 (a C&M case), the Armed Services Board of Contract Appeals (Board) held that the contractor’s claim, seeking recovery for impacts of over-and-above repair work during contract performance, was timely filed under the Contract Disputes Act’s six-year statute of limitations—rejecting an Air Force Motion for Summary Judgment and granting cross-motions filed on behalf of Lockheed Martin.  Recognizing that a contractor’s claim cannot accrue before the events that fix the liability of the government, the Board held Lockheed Martin’s claim did not have a single accrual date but, rather, multiple accrual dates based upon when the government approved each repair.  The Board separately held that those government approvals represented “the type of single-topic . . . yet repeated and distinct events” making Lockheed Martin’s claims timely under the well-recognized “continuing claim doctrine.”

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Client Alert | 4 min read | 11.18.25

DOJ Announces Major Enforcement Actions Targeting North Korean Remote IT Worker Schemes

On November 14, 2025, the U.S. Department of Justice (DOJ) announced a sweeping series of enforcement actions, including four guilty pleas and more than $15 million in civil forfeitures against the  Democratic People’s Republic of Korea (DPRK or North Korea) for remote information technology (IT) worker schemes. These actions underscore the federal government’s escalating focus on the exposure of U.S. companies to North Korean IT worker infiltration, following a series of U.S. Government action against the DPRK....