Awards Reinstated After Faulty 'Corrective Action'
Client Alert | less than 1 min read | 04.11.14
In WHR Group, Inc. v. U.S. (Apr. 8, 2008), the Court of Federal Claims set aside an agency's "corrective action" terminating three blanket purchase agreements for employee relocation services because that action was not narrowly tailored to address the flaw in the underlying procurement. While the agency cited a laundry list of reasons for why it believed termination and reprocurement was necessary, Judge Block rejected nearly all of them and, as to the one issue that legitimately raised a concern about the prior evaluation, he concluded that a reevaluation would address the problem without a full resolicitation.
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Client Alert | 5 min read | 08.21.26
FTC Proposes Enforcement Policy Statement on Personalized Pricing: What Businesses Need to Know
On August 19, 2026, the Federal Trade Commission (FTC) announced a proposed Enforcement Policy Statement on personalized pricing — the practice of companies using consumers’ personal data to set individualized prices, discounts, coupons, or other incentives. The proposed statement, which is open for public comment for 30 days following publication in the Federal Register, marks a major step up in the FTC’s focus on data-driven pricing strategies and puts businesses across industries on notice that undisclosed or inadequately disclosed personalized pricing will not be tolerated. Importantly, while the proposed statement is not a binding legal requirement and does not create new legal obligations, it serves as an enforcement warning that the FTC is prepared to use its existing enforcement authority under Section 5 of the FTC Act (Section 5) and is also a potential harbinger of rulemaking. Businesses that engage in — or are considering — personalized pricing should carefully assess their disclosure practices and data collection procedures against the standards articulated in this statement.
Client Alert | 7 min read | 08.19.26
CMS’s Final Rule Bans Federal Medicaid Funding for Youth Gender-Affirming Care
Client Alert | 2 min read | 08.19.26
