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GSA Schedule Prices No Longer Presumed Reasonable at DoD

Client Alert | less than 1 min read | 04.07.14

On March 13, 2014, DoD issued a class deviation to FAR 8.404(d) that could make orders under GSA Schedule contracts more burdensome for both contractors and DoD, directing that contracting officers can no longer rely upon GSA's determination of price reasonableness and must instead conduct their own price analysis using the techniques in FAR 15.404-1. When the award is not competitive, those price analysis techniques could include evaluation of prices charged in similar sales or, if it is the only means to determine that the price is reasonable, could even include obtaining cost data to support the pricing of these commercial contracts.


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Client Alert | 3 min read | 09.17.25

The “Climate Cartel” – U.S. State AGs Cite Antitrust and Consumer Protection Concerns to Take Aim at Domestic and International Organizations

On August 8, 2025, the Attorneys General of 23 Republican-led U.S. states (the “AGs”) sent a letter to Science Based Targets Initiative (“SBTi”), a U.K. non-profit climate organization, expressing concern with the SBTi’s climate initiatives.[1]SBTi had previously received a subpoena from Florida Attorney General James Uthmeier in connection with his office’s investigation into what he described as a “climate cartel,” which he alleges includes SBTi and CDP (formerly the Carbon Disclosure Project).[2]...