GSA Seeks Input on Acquisition Regulations, Including the Alphabet Soup of TDR, PRC, and CSP
Client Alert | 1 min read | 05.30.17
In accordance with President Trump’s continuing mandate to streamline federal regulations, GSA is seeking input on its acquisition regulations, policies, and guidance that may be appropriate for repeal, replacement, or modification. GSA is particularly interested in comments on less frequently addressed areas such as evergreen contracting, price adjustments, catalogs, utilities, construction, and facilities. However, GSA is also welcoming comments on bigger ticket items such as the recent Transactional Data Reporting (TDR) rule, the Price Reduction Clause (PRC), and the Commercial Sales Practice (CSP) format. Comments are due in late July, and will provide interested parties an invaluable opportunity to address a broad swath of GSA’s existing policies and practices. Indeed, with recent indications that compliance with TDR requirements may soon become optional, this request for input appears very well timed to assist GSA in making important decisions for the Schedule program going forward.
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Client Alert | 5 min read | 12.12.25
Eleventh Circuit Hears Argument on False Claims Act Qui Tam Constitutionality
On the morning of December 12, 2025, the Eleventh Circuit heard argument in United States ex rel. Zafirov v. Florida Medical Associates, LLC, et al., No. 24-13581 (11th Cir. 2025). This case concerns the constitutionality of the False Claims Act (FCA) qui tam provisions and a groundbreaking September 2024 opinion in which the United States District Court for the Middle District of Florida held that the FCA’s qui tam provisions were unconstitutional under Article II. See United States ex rel. Zafirov v. Fla. Med. Assocs., LLC, 751 F. Supp. 3d 1293 (M.D. Fla. 2024). That decision, penned by District Judge Kathryn Kimball Mizelle, was the first success story for a legal theory that has been gaining steam ever since Justices Thomas, Barrett, and Kavanaugh indicated they would be willing to consider arguments about the constitutionality of the qui tam provisions in U.S. ex rel. Polansky v. Exec. Health Res., 599 U.S. 419 (2023). In her opinion, Judge Mizelle held (1) qui tam relators are officers of the U.S. who must be appointed under the Appointments Clause; and (2) historical practice treating qui tam and similar relators as less than “officers” for constitutional purposes was not enough to save the qui tam provisions from the fundamental Article II infirmity the court identified. That ruling was appealed and, after full briefing, including by the government and a bevy of amici, the litigants stepped up to the plate this morning for oral argument.
Client Alert | 8 min read | 12.11.25
Director Squires Revamps the Workings of the U.S. Patent Office
Client Alert | 8 min read | 12.10.25
Creativity You Can Use: CJEU Clarifies Copyright for Applied Art
Client Alert | 4 min read | 12.10.25
Federal Court Strikes Down Interior Order Suspending Wind Energy Development
