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Customary Commercial Practice Deserves Respect

Client Alert | less than 1 min read | 10.03.12

In Verizon Wireless (Sept. 17, 2012), GAO sustained a solicitation protest in a FAR Subpart 8.4 procurement for a blanket purchase agreement for wireless telecommunications devices and services off the Federal Supply Schedule when the agency had selected contract terms and conditions that were inconsistent with customary commercial practice in the industry. GAO concluded that the agency had failed to conduct the necessary market research to realize that the disputed terms were irregular and, thus, had failed to prepare the mandatory, documented determination of why it was necessary to deviate from normal commercial practice.


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Client Alert | 4 min read | 01.14.26

PFAS Reporting Gets Real in 2026

State regulation of PFAS-containing products will ramp up significantly in 2026. Most notably, companies will have to comply with Minnesota’s sweeping new product-reporting requirements.  As we explain below, Minnesota’s requirements cast a wide net, capturing companies that may not sell products directly into the state. This and other features of the state’s reporting program are likely to present significant compliance challenges for a wide range of businesses....