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Environmental Petitioners ask Second Circuit for Rehearing

Client Alert | 1 min read | 04.15.05

Environmental Petitioners yesterday (April 14, 2005) asked the Second Circuit for a rehearing on a critical element of the court's February 28, 2005 decision on EPA's 2003 CAFO Rulemaking. Waterkeeper Alliance, Inc. et al. v. EPA, (No. 03-4470, et al.). The pleading asks the court to overturn its decision that CAFOs do not have a "duty to apply" for an NPDES permit. The pleading also asks the court — if it refuses to reverse itself on the "duty to apply" issue — to require CAFOs to have an approved nutrient management plan in an NPDES permit to qualify for the "agricultural stormwater" exemption from NPDES permitting.

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Client Alert | 1 min read | 04.18.24

GSA Clarifies Permissibility of Upfront Payments for Software-as-a-Service Offerings

On March 15, 2024, the General Services Administration (GSA) issued Acquisition Letter MV-2024-01 providing guidance to GSA contracting officers on the use of upfront payments for acquisitions of cloud-based Software-as-a-Service (SaaS).  Specifically, this acquisition letter clarifies that despite statutory prohibitions against the use of “advance” payments outside of narrowly-prescribed circumstances, upfront payments for SaaS licenses do not constitute an “advance” payment subject to these restrictions when made under the following conditions:...