CFC Rejects Yet Another Government Argument to Extend CDA Statute of Limitations
Client Alert | 1 min read | 08.15.12
In yet another recent CDA statute of limitations decision, the Court of Federal Claims in Raytheon Company v. United States (July 26, 2012) denied the government's motion for reconsideration of its April 2012 decision holding that the CO's final decision was barred by the six-year SOL. In its motion, the government argued that it was entitled by FAR 31.201-2 to complete an audit before the SOL could begin to run, but the CFC rejected that argument, holding that "the statute of limitations begins to run when information that equates to knowledge of a potential claim becomes available to the Government" and that under this standard the government was "on notice" of a potential claim against the contractor based on information it obtained when it entered into an advance agreement with Raytheon in 1999 about the costs at issue.
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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

