Federal Circuit Extends 'Good Faith' Shield of Agencies
Client Alert | less than 1 min read | 08.12.13
In Croman Corp. v. U.S. (July 31, 2013), the Federal Circuit upheld the reasonableness of an agency's corrective action after expanding the protestor's argument into a "bad faith" allegation. When the protestor complained that the cancellation of several CLINs was without a rational basis and put forward evidence that indicated the agency's rationale was pretextual, instead of requiring the agency to put forward proof to support its stated rationale, the court relabeled the challenge as a "bad faith" allegation, which it held the protestor had not shown by clear and convincing evidence.
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Client Alert | 4 min read | 04.08.26
Cosmetics Under the Microscope: FDA’s Expanding Regulatory Reach Under MoCRA
The Modernization of Cosmetics Regulation Act of 2022 (MoCRA) marked the most significant expansion of FDA’s authority over cosmetics in 80 years — and the agency is putting that authority to work. From the launch of a new adverse event reporting tool to forthcoming rules on fragrance allergens and good manufacturing practices (GMP), FDA is reshaping the regulatory landscape for manufacturers, packers, and distributors of cosmetic and personal care products.
Client Alert | 11 min read | 04.08.26
Client Alert | 3 min read | 04.07.26
Answering the Top Seven Questions About Pending Section 301 Deadlines
