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Board Clarifies that Claim Accrual Contains Implicit "Reasonableness" Standard

Client Alert | 1 min read | 06.07.17

In Sparton DeLeon Springs, LLC (ASBCA No. 60416, May 18, 2017), the Board denied the government’s request for reconsideration of an earlier Board decision, which had rejected the government’s claim for recoupment of alleged overpayments of direct costs as time-barred by the CDA's six-year statute of limitations (previously discussed in a blog post). In support of this reconsideration decision, and in response to the government’s argument that "the Board applied the wrong legal standard for determining whether the claim had accrued," the Board explained that it saw "no conceptual difference between the 'should have been known' standard set forth in [FAR] 33.201" and "the phrase 'reasonably should have known' recited by the government" because "the one expresses only what the other implies."

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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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