1. Home
  2. |Insights
  3. |Conflict of Interest by Government Official

Conflict of Interest by Government Official

Client Alert | less than 1 min read | 11.23.15

In Satellite Tracking of People, LLC (Nov. 6, 2015), GAO sustained what it called a first-of-kind protest concerning a government program manager who had been recently employed by one of the competitors in the procurement. Because the CO had stated in writing prior to proposal submission that the program manager should recuse herself, yet never followed through to enforce the recusal, GAO concluded that a known conflict of interest concern had been left unresolved and, therefore, prejudice to the protester arising from this conflict must be presumed.


Contacts

Insights

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....

View All Insights