DoD Rescinds IR&D "Technical Interchange" Requirement
Client Alert | 1 min read | 09.04.18
On August 24, 2018, the Department of Defense (DoD), issued a final rule that, effective immediately, removes the requirement in Defense Federal Acquisition Regulation Supplement (DFARS) 231.205–18(c)(iii)(C)(4) that major contractors conduct a formal discussion (i.e., “technical interchange”) with a DoD technical staffer prior to generating independent research and development (IR&D) costs for IR&D projects initiated in fiscal year 2017 and later, in order for those costs to be allowable. The requirement applied to major contractors, who are defined as contractors whose covered segments allocated a total of more than $11 million in IR&D and bid proposal costs to covered contracts during the preceding fiscal years. The requirement was repealed after a determination by the DoD Regulatory Reform Task Force that the DFARS requirement was unnecessary since the objective of the interchange “can be met through other means.”
Contacts
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
