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Federal Circuit Drops Bombshells on CDA Statute of Limitations and CAS "Materiality" Test

Client Alert | less than 1 min read | 12.11.14

In Sikorsky Aircraft Corp. v. U.S., the Federal Circuit upended the prevailing case law on the CDA statute of limitations by holding that the six-year SOL for filing CDA claims is "not jurisdictional" and "need not be addressed before deciding the merits." In denying the merits of the government's $80 million CAS 418 claim, the Federal Circuit also held that the cost of Sikorsky's management and supervision was "not a material amount of the total pool costs" because managers/supervisors comprised only 7 to 14 percent of the pertinent workforce, clarifying that materiality requires "a significant amount."


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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....

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