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A New Dawn or New Nightmare: Will Transactional Data Reporting Reduce, or Merely Shift, GSA Schedule Contractors' Compliance Burden?

Client Alert | 1 min read | 06.23.16

Despite competing concerns expressed by both contractors and the IG, on June 23, 2016, GSA published a final rule proceeding with a pilot program imposing substantial monthly transactional data reporting obligations on contractors but relieving them from the burden of both commercial sales practices data submissions and the monitoring of commercial sales to tracking customers, as well as from the threat of price readjustments and possible FCA liability under the Price Reduction clause. The pilot program will initially apply to new contracts (and existing contracts where contractors elect to participate) under select GSA Schedules accounting for approximately 43 percent of GSA Schedule purchases, including Schedule 70 (Information Technology) and 00CORP (Professional Services), and continue for at least one year as GSA evaluates its ability effectively to collect and use transactional data and price analysis to assure better pricing for GSA Schedule customers.

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Client Alert | 4 min read | 12.04.25

District Court Grants Preliminary Injunction Against Seller of Gray Market Snack Food Products

On November 12, 2025, Judge King in the U.S. District Court for the Western District of Washington granted in part Haldiram India Ltd.’s (“Plaintiff” or “Haldiram”) motion for a preliminary injunction against Punjab Trading, Inc. (“Defendant” or “Punjab Trading”), a seller alleged to be importing and distributing gray market snack food products not authorized for sale in the United States. The court found that Haldiram was likely to succeed on the merits of its trademark infringement claim because the products at issue, which were intended for sale in India, were materially different from the versions intended for sale in the U.S., and for this reason were not genuine products when sold in the U.S. Although the court narrowed certain overbroad provisions in the requested order, it ultimately enjoined Punjab Trading from importing, selling, or assisting others in selling the non-genuine Haldiram products in the U.S. market....