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Federal Employees as Relators OK'ed

Client Alert | less than 1 min read | 08.07.12

In Little v. Shell Exploration & Production Co., the Fifth Circuit joined the Tenth and Eleventh Circuits in holding that federal employees, like private citizens, can bring whistleblower suits under the False Claims Act--even when those employees are auditors whose job is to investigate fraud. The Sixth and Ninth Circuits have also implicitly held that federal employees are not barred from acting as relators, while the First Circuit has held that at least some federal employees may not be qui tam plaintiffs.

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Client Alert | 1 min read | 04.18.24

GSA Clarifies Permissibility of Upfront Payments for Software-as-a-Service Offerings

On March 15, 2024, the General Services Administration (GSA) issued Acquisition Letter MV-2024-01 providing guidance to GSA contracting officers on the use of upfront payments for acquisitions of cloud-based Software-as-a-Service (SaaS).  Specifically, this acquisition letter clarifies that despite statutory prohibitions against the use of “advance” payments outside of narrowly-prescribed circumstances, upfront payments for SaaS licenses do not constitute an “advance” payment subject to these restrictions when made under the following conditions:...