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25th Anniversary Version Of FMF Guidelines -- No Celebration For It Companies

Client Alert | less than 1 min read | 09.10.09

On August 31, 2009, the Defense Security Cooperation Agency released a revised set of Guidelines for Foreign Military Financing of Direct Commercial Contracts and Contractor's Certification & Agreement with DSCA which are to be implemented no later than October 1, 2009. The principal changes focus on the difficult compliance issue of identifying non-U.S. content in the products and underscore DSCA's increasingly inflexible approach to that issue, including determination whether spares and post-delivery warranty or maintenance effort constitute non-U.S. content ineligible for financing, a problem that has been particularly troubling for companies furnishing information technology products to the Government of Israel under the FMF program.

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Client Alert | 3 min read | 07.18.25

Eighth Circuit Cancels Click-to-Cancel

On July 8, 2025, the Eighth Circuit vacated the Federal Trade Commission’s (“FTC”) Negative Option Rule, also known as the Click-to-Cancel Rule, on procedural grounds. The Click-to-Cancel Rule, which provided a streamlined path for consumers to cancel subscription services in a few clicks of a mouse, was scheduled to take effect on July 14, 2025, but the Court found that the FTC had failed to follow mandatory procedural requirements....