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BPAs: They Ain't Contracts

Client Alert | less than 1 min read | 02.14.14

In Crewzers Fire Crew Transport, Inc. v. U.S. (Feb. 6, 2014), the Federal Circuit reaffirmed that a blanket purchase agreement is not typically a binding contract on which the contractor can sue. In this instance, as in many, the necessary "mutuality of obligation" was negated in both directions, with the BPA expressly saying the agency was not obligated to make an award under the BPA and that the contractor was not obligated to accept any order proffered by the agency.


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Client Alert | 2 min read | 09.18.25

FDA Announces Intention to Initiate an Aggressive Enforcement Campaign Against Misleading Pharmaceutical Advertising

On September 9, 2025, the U.S. Department of Health and Human Services (HHS) and the Food and Drug Administration (HHS) issued a news release announcing an “aggressive[]” “crackdown” on direct-to-consumer pharmaceutical advertising. This release came on the heels of a Presidential Memorandum President Trump issued the same day directing HHS to “ensure transparency and accuracy in direct-to-consumer prescription drug advertisements,” and the FDA to “take action to enforce legal requirements that advertisements for prescription drugs be truthful and not misleading.”...