Blanket Purchase Order Does Not Equal Task Order Contract
Client Alert | less than 1 min read | 01.19.10
In C & B Constr., Inc. (Jan. 6, 2010), GAO explained that it had jurisdiction to review protests of task orders issued under Blanket Purchase Agreements ("BPA"), even if the task order is valued less than $10 million (the statutory limit for GAO to review protests of task or delivery order contracts), because BPAs are different from task or delivery order contracts. GAO then sustained the protest because the source selection decision was based on numerical scores without adequate substantive discussion.
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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.
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CMS’s Final Rule Bans Federal Medicaid Funding for Youth Gender-Affirming Care
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