Costs of Air Travel Limited to the “Lowest Priced Airfare Available to the Contractor”
Client Alert | 1 min read | 12.14.09
By a final rule effective January 11, 2010, the travel cost principle (FAR 31.205-46) has been amended to limit the cost of air travel to the “lowest priced airfare available to the contractor,” except in limited circumstances. Instead of simply limiting a contractor's recovery of air travel costs for employees who are authorized to fly in premium classes to the lowest airfare available to that particular contractor based on agreements that particular contractor has negotiated with an airline – which is the stated purpose of the amendment – the new rule uses confusing language that is likely to be misinterpreted as imposing a broader limit on allowability that will be virtually impossible to administer in light of the variability in the price of air travel, including even different fares on the same flight, both for employees who are actually charged non-premium fares that are greater than the lowest theoretically "available" fare to a particular contractor and on the many contractors that do not even have negotiated agreements with airlines.
Insights
Client Alert | 4 min read | 12.04.25
District Court Grants Preliminary Injunction Against Seller of Gray Market Snack Food Products
On November 12, 2025, Judge King in the U.S. District Court for the Western District of Washington granted in part Haldiram India Ltd.’s (“Plaintiff” or “Haldiram”) motion for a preliminary injunction against Punjab Trading, Inc. (“Defendant” or “Punjab Trading”), a seller alleged to be importing and distributing gray market snack food products not authorized for sale in the United States. The court found that Haldiram was likely to succeed on the merits of its trademark infringement claim because the products at issue, which were intended for sale in India, were materially different from the versions intended for sale in the U.S., and for this reason were not genuine products when sold in the U.S. Although the court narrowed certain overbroad provisions in the requested order, it ultimately enjoined Punjab Trading from importing, selling, or assisting others in selling the non-genuine Haldiram products in the U.S. market.
Client Alert | 21 min read | 12.04.25
Highlights: CMS’s Proposed Rule for Medicare Part C & D (CY 2027 NPRM)
Client Alert | 11 min read | 12.01.25
