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Goodbye DUNS Numbers; Hello ??

Client Alert | less than 1 min read | 10.04.16

A final rule published September 30 and effective October 31, 2016, removes all references to the DUNS number in the FAR because usage of a proprietary number and organization to meet the government’s identification needs limits competition. The FAR Council did not provide a specific alternative to the DUNS number, instead indicating that OMB and Treasury are taking the lead in considering such alternatives – a process that will include input from the private sector about “nonproprietary” options.

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Client Alert | 3 min read | 07.18.25

Eighth Circuit Cancels Click-to-Cancel

On July 8, 2025, the Eighth Circuit vacated the Federal Trade Commission’s (“FTC”) Negative Option Rule, also known as the Click-to-Cancel Rule, on procedural grounds. The Click-to-Cancel Rule, which provided a streamlined path for consumers to cancel subscription services in a few clicks of a mouse, was scheduled to take effect on July 14, 2025, but the Court found that the FTC had failed to follow mandatory procedural requirements....