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GSA Panel to Discuss New Section 889 Interim Rule Implementation

Client Alert | 2 min read | 07.29.20

Last week, the General Services Administration (GSA) announced that the Office of Governmentwide Policy would hold a live and recorded virtual webinar panel on August 12, 2020 to discuss the new interim rule implementing the 2019 National Defense Authorization Act Section 889(a)(1)(B) covered telecommunications prohibition. 

The panel is expected to address the implementation and application of the new interim rule and answer the public’s pre-submitted questions.  Panelists will include Directors and Division Directors from offices of the Federal Acquisition Service and Public Building Service, including:

  • Multiple Awards Schedule Program Management Office
  • City Pair Program, Office of Travel, Employee Relocation, and Transportation
  • IT Security Subcategory, Office of Information Technology Category
  • Vehicle Purchasing Division, Office of Motor Vehicle Management
  • Special Programs Division, Office of Project Delivery, Office of Design and Construction
  • Innovation Technology and Performance Division, Office of Facilities Management
  • Lease Policy and Innovation Division, Office of Leasing

Questions may be submitted until August 5 at 5:00 p.m. Eastern.  Attendees must register.

DoD also issued guidance last week for Section 889 implementation that provides guidance to contracting officers generally and describes the role of the contracting officer in evaluating whether use of covered telecommunications equipment is a substantial or essential component of a system and whether an exception otherwise applies.

For a discussion of the new interim rule, see our July 14 summary of the new rule or our July 17 webinar addressing the nuances of the new rule.  

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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....