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A GSA Schedule Buy Must Be All Schedule

Client Alert | less than 1 min read | 02.07.05

In KEI Pearson, Inc. (Jan. 10, 2005), the GAO reaffirmed the rule "Non-FSS products may not be purchased using FSS procedures." There, GAO sustained the protest of a GSA schedule procurement because the awardee proposed to acquire certain commercial off-the-shelf software through a lower cost, non-schedule “alliance agreement” between the awardee and the software vendor, rather that proposing to use a more expensive GSA schedule vendor, of which there were many.

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Client Alert | 6 min read | 11.26.25

From ‘Second’ to ‘First:’ Federal Circuit Tackles Obvious Claim Errors

Patent claims must be clear and definite, as they set the boundaries of the patentee’s rights. Occasionally, however, claim language contains errors, such as typographical mistakes or incorrect numbering. Courts possess very limited authority to correct such errors. The United States Court of Appeals for the Federal Circuit has emphasized that judicial correction is appropriate only in rare circumstances, where (1) the error is evident from the face of the patent, and (2) the proposed correction is the sole reasonable interpretation in view of the claim language, specification, and prosecution history. See Group One, Ltd. v. Hallmark Cards, Inc., 407 F.3d 1297, 1303 (Fed. Cir. 2005) and Novo Indus., L.P. v. Micro Molds Corp., 350 F.3d 1348, 1357 (Fed. Cir. 2003)....