Awardees in Multiple-Award Procurements Can Challenge Award Decisions to Fellow Awardees
Client Alert | 1 min read | 05.16.16
In Nat’l Air Cargo, Inc. v. U.S. (Apr. 28, 2016), the CFC concluded that awardees in a procurement contemplating the award of multiple IDIQ contracts are interested parties with standing to challenge the validity of the awards to other contract awardees in the procurement. In a significant departure from GAO's stance of the issue, the court held that, even when all task order work under the IDIQ is to be competed at a later date, each awardee suffers a non-trivial injury from the improper addition to the original pool of awardees because the size of the pool has a material impact on the likelihood of winning future task order work.
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Client Alert | 5 min read | 08.21.26
FTC Proposes Enforcement Policy Statement on Personalized Pricing: What Businesses Need to Know
On August 19, 2026, the Federal Trade Commission (FTC) announced a proposed Enforcement Policy Statement on personalized pricing — the practice of companies using consumers’ personal data to set individualized prices, discounts, coupons, or other incentives. The proposed statement, which is open for public comment for 30 days following publication in the Federal Register, marks a major step up in the FTC’s focus on data-driven pricing strategies and puts businesses across industries on notice that undisclosed or inadequately disclosed personalized pricing will not be tolerated. Importantly, while the proposed statement is not a binding legal requirement and does not create new legal obligations, it serves as an enforcement warning that the FTC is prepared to use its existing enforcement authority under Section 5 of the FTC Act (Section 5) and is also a potential harbinger of rulemaking. Businesses that engage in — or are considering — personalized pricing should carefully assess their disclosure practices and data collection procedures against the standards articulated in this statement.
Client Alert | 7 min read | 08.19.26
CMS’s Final Rule Bans Federal Medicaid Funding for Youth Gender-Affirming Care
Client Alert | 2 min read | 08.19.26
