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Crossing The Threshold

Client Alert | 1 min read | 01.22.08

In a memorandum dated January 7, 2008, GSA's Senior Procurement Executive, David Drabkin, acknowledged that "currently there is no government-wide standard that addresses" whether the Trade Agreements Act (TAA) threshold (soon to rise to $194,000) applies at the order level or the contract value level for GSA multiple award contracts and is seeking to have all GSA Contracting Activities weigh in on the issue. Largely at the instigation of the IT industry which, back in the 1980s, wanted to be freed of counting component costs under the Buy American Act regulatory test for domestic end products, GSA has traditionally applied the TAA threshold to the total expected contract value for GSA Schedule contracts, but now given the Buy American Act exemption for commercial IT products contained in FAR 25.103(e), certain companies might well find it advantageous if the threshold were to be applied at the order level.

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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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