"//signed//" Doesn't Cut It
Client Alert | less than 1 min read | 04.30.08
A claim certification was invalid, and the ASBCA had no jurisdiction to decide the case, when the contractor's president submitted it by email and simply typed "//signed//" above his name. The Board in Teknocraft Inc. (Apr. 3, 2008) acknowledged that both the contractor and the government had used the typed designation "//signed//" in their emails during performance, but held that "//signed//" was not a "discrete, verifiable symbol of an individual" and constituted an "incurable defect" in the certification.
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Client Alert | 2 min read | 05.14.26
On May 7, 2026, the Department of War issued the long-awaited Proposed Rule to implement Section 847 of the FY 2020 National Defense Authorization Act (NDAA) regarding Foreign Ownership, Control or Influence (FOCI) requirements for contractors. The proposed rule would expand the applicability of FOCI reviews, requiring contractors and subcontractors on unclassified “covered contracts” — defense contracts and subcontracts valued in excess of $5 million that are not for commercial products and services — to submit FOCI disclosures to the Defense Counterintelligence and Security Agency (DCSA) for FOCI risk assessment (and as applicable, mitigation) as part of contract award. This would effectively require DCSA assessment and adjudication of FOCI considerations prior to contract award. Thus, both cleared and uncleared defense contractors would be subject to the rigorous DCSA disclosure requirements, scrutiny, and FOCI mitigation. Crowell discussed the Section 847 requirements in a prior alert.
Client Alert | 4 min read | 05.14.26
Client Alert | 6 min read | 05.12.26
Client Alert | 5 min read | 05.12.26
NYDFS Ramps Up Health Care Cybersecurity Enforcement With $2.25 Million Settlement
