Attribution of Affiliate Past Performance Improper Without Proposed Meaningful Involvement in Performance
Client Alert | 1 min read | 12.11.17
In a recent protest decision, Language Select LLP, dba United Language Group (released Dec. 1, 2017), GAO sustained a protest of a Federal Supply Schedule blanket purchase agreement by the Social Security Administration for worldwide telephone interpreter services because the agency improperly credited the awardee with the experience and past performance of a subsidiary division based on identification of the division on the awardee’s stationary and in its FSS contract, even though the awardee’s proposal made no mention of the division’s resources nor any meaningful involvement in the awardee’s performance under the BPA, holding that common management is insufficient to support awarding past performance credit for an affiliate. GAO also sustained on the bases that the agency held unequal discussions with the awardee and the agency failed to provide (and document) a rational basis for discounting the significance of the awardee’s recent termination for cause on a similar contract.
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Client Alert | 4 min read | 12.31.25
Raising the Bar: New York Expands Consumer Protection Law with FAIR Business Practices Act
New York Governor Kathy Hochul has signed into law the most significant update to New York’s consumer protection law in 45 years — the Fostering Affordability and Integrity through Reasonable Business Practices Act, or FAIR Business Practices Act — expanding the scope of the state’s authority to now challenge unfair and abusive business practices. The measure, backed by New York Attorney General (“AG”) Letitia James and signed on December 19, 2025, amends New York’s General Business Law § 349, giving regulators new tools to protect consumers and promote fair marketplace practices.
Client Alert | 4 min read | 12.30.25
Client Alert | 6 min read | 12.30.25
Investor Advisory Committee Recommends SEC Disclosure Guidelines for Artificial Intelligence
Client Alert | 2 min read | 12.29.25
FYI – GAO Finds Key Person “Available” Despite Accepting Employment with a Different Company


