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A-76 Mix And Match Faulted By GAO

Client Alert | less than 1 min read | 08.16.04

In Career Quest (Aug. 2, 2004), GAO sustained a protest of the GSA's decision under OMB Circular A-76 that it was more economical to continue performance of services in-house at the National Customer Support Center, as the agency evaluated the in-house offeror's technical performance plan based on a higher level of staffing than the same offeror included in its cost of performance. Inconsistencies between in-house offerors' staffing levels for compliance with work requirements and those it uses for calculating the cost of performance remain a persistent problem in A-76 competitions, and this decision sends the message that GAO will be alert to such shell games.

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Client Alert | 6 min read | 11.25.25

Brussels Court Clarifies the EU’s SPC Manufacturing Waiver Regulation Rules

On November 13, 2025, the president of the French-speaking Brussels Enterprise Court ruled in the long-running battle between Sandoz and Regeneron about the correct interpretation of the EU’s Supplementary Protection Certificate (SPC) Manufacturing Waiver Regulation regarding exports to a non-EU market. The Brussels Court dismissed Regeneron’s claim that Sandoz had provided a defective notification and agreed with Sandoz’s interpretation of the Regulation....