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EEOC Announces it will Require both 2017 and 2018 W-2 Data By September 30, 2019 . . . But the Saga Continues

Client Alert | 1 min read | 05.06.19

The government took two significant steps on Friday regarding the battle over the EEO-1 pay data. Most notably, in response to Judge Tanya Chutkan’s recent ruling, the EEOC issued a Rule requiring employers with 100 or more employees and federal contractors with 50 or more employees to file “Component 2” W-2 earnings data for calendar year 2017 by September 30, 2019. This requirement is in addition to the mandate that such employers submit “Component 2” W-2 data for calendar year 2018 by that same date. The EEOC stated that it believes its portal will be open to receive such filings by mid-July 2019. On the same day, the Department of Justice filed a notice of appeal of Judge Chutkan’s ruling, so the fight over the EEO-1 pay data requirements will continue. However, the appeal does not stay Judge Chutkan’s ruling, so employers should prepare to file both 2017 and 2018 data by September 30th and should stay tuned, as this saga continues.

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Client Alert | 2 min read | 04.16.26

Federal Circuit Holds Challengers to CICA Stay Overrides Need Not Satisfy Four-Factor Injunctive Relief Test

In a significant decision for government contractors, on April 15, 2026, in Life Science Logistics, LLC v. United States, the U.S. Court of Appeals for the Federal Circuit held that bid protesters challenging an agency’s override of an automatic stay of contract performance under the Competition in Contracting Act (CICA) need not satisfy the demanding four-factor test traditionally required for preliminary injunctive relief.  In so doing, the Federal Circuit clarified that CICA stay override challenges need only demonstrate that the override decision was arbitrary and capricious—nothing more....

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