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Accurate Historical Data Yields Negligent Estimate

Client Alert | 1 min read | 02.28.17

In Agility Def. & Gov’t Servs., Inc. v. United States (Feb. 6, 2017), the Court of Appeals for the Federal Circuit held that the government’s volume estimate in a requirements-contract solicitation cannot rely solely on historical workloads when the government expects conditions to change going forward. FAR 16.503 requires solicitations for requirements contracts to include a “realistic estimate of total quantity” based on “the most current information available.” Reversing a decision from the Court of Federal Claims, the CAFC revived the contractor’s negligent-estimate claim, holding that the government failed to comply with FAR 16.503 when its estimate relied on historical data rather than the agency’s actual expectation that changing conditions would create a surge in requirements above and beyond the historical workloads.

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Client Alert | 4 min read | 04.15.26

In Massachusetts, Section 230 Does Not Immunize Meta From Claims That Instagram’s Design Features Injure Children

Meta continues to face lawsuits around the country alleging that its platforms are designed to induce compulsive use by children. In March 2026, a California jury delivered a landmark verdict that Meta and YouTube were liable for allegedly addictive platform features that resulted in a child’s mental health distress.  ...