DOD Revises IP Commercial Item Rules
Client Alert | less than 1 min read | 09.21.11
On September 20, 2011, DOD issued a final rule amending DFARS Part 227 and the associated clauses to eliminate the presumption of development at private expense for commercial items (other than commercially available off-the-shelf items) for major systems or subsystems. However, the implementation of this rule introduces great uncertainty as to the government’s rights to commercial item technical data and commercial computer software when there has been even a minimal government investment, particularly as it relates to the applicability of commercial licenses and marking requirements.
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Client Alert | 14 min read | 03.13.26
AI for Government: 7 Days for Contractor Comments on GSA Proposed Contract Clause for AI Systems
On March 6, 2026, the General Services Administration (GSA) issued a significant proposed contract clause, GSAR 552.239-7001, Basic Safeguarding of Artificial Intelligence Systems (“Clause”), for inclusion in GSA Schedule solicitations and contracts for AI capabilities. The proposed clause would impose substantial new requirements related to AI sources, intellectual property rights, data use, change management, and performance standards. The Clause would also take precedence over any other contract terms (including commercial licensing terms) related to AI, including a Seller’s terms of sale and service to which the Government had previously agreed. GSA requests comments by March 20, 2026.
Client Alert | 3 min read | 03.12.26
DOJ Releases First-Ever Department-Wide Corporate Enforcement and Voluntary Self-Disclosure Policy
Client Alert | 3 min read | 03.12.26
