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Approved: E-Signatures for CDA Claim Certifications Receive the ASBCA’s Stamp of Approval

Client Alert | 1 min read | 10.30.19

In URS Federal Services, Inc., ASBCA 61443 (October 3, 2019), the Armed Services Board of Contract Appeals addressed whether a contractor’s digital signature complied with the CDA’s claim certification requirements. The signature in question was electronically affixed to the claim document—along with a digital certificate—using software that required the signer to input a unique password and user identification before signing. The government argued that one “cannot trust the [digital] certificate to prove the identity of the person who applied it,” because there was no “suitable ID” to prove the signer’s identity. While noting that it had previously found typed but unsigned names to be insufficient, the Board rejected the government’s argument, because the digital signature was “discrete” and “verifiable” in accordance with the CDA’s requirements. The Board reasoned that “[n]o ink signature, on its face, includes any way for the reader to know who executed it unless that reader already possesses an intimate familiarity with the certifier’s handwriting” and declined to “impose draconian demands on digital signatures, not required to be met for their ink counterparts.” 


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Client Alert | 5 min read | 12.12.25

Eleventh Circuit Hears Argument on False Claims Act Qui Tam Constitutionality

On the morning of December 12, 2025, the Eleventh Circuit heard argument in United States ex rel. Zafirov v. Florida Medical Associates, LLC, et al., No. 24-13581 (11th Cir. 2025). This case concerns the constitutionality of the False Claims Act (FCA) qui tam provisions and a groundbreaking September 2024 opinion in which the United States District Court for the Middle District of Florida held that the FCA’s qui tam provisions were unconstitutional under Article II. See United States ex rel. Zafirov v. Fla. Med. Assocs., LLC, 751 F. Supp. 3d 1293 (M.D. Fla. 2024). That decision, penned by District Judge Kathryn Kimball Mizelle, was the first success story for a legal theory that has been gaining steam ever since Justices Thomas, Barrett, and Kavanaugh indicated they would be willing to consider arguments about the constitutionality of the qui tam provisions in U.S. ex rel. Polansky v. Exec. Health Res., 599 U.S. 419 (2023). In her opinion, Judge Mizelle held (1) qui tam relators are officers of the U.S. who must be appointed under the Appointments Clause; and (2) historical practice treating qui tam and similar relators as less than “officers” for constitutional purposes was not enough to save the qui tam provisions from the fundamental Article II infirmity the court identified. That ruling was appealed and, after full briefing, including by the government and a bevy of amici, the litigants stepped up to the plate this morning for oral argument....

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