Interim Rule Eliminates CO Pricing Review of Indirect Offset Costs
Client Alert | less than 1 min read | 06.02.15
Today, DoD issued an interim rule immediately relieving contracting officers (COs) of responsibility for performing a price reasonableness analysis of the costs associated with indirect offsets when mandated by a foreign government customer under a Foreign Military Sales (FMS) contract. The revised rule responds to a "foreseeable trend of increasing numbers and complexity of indirect offsets" on which FMS customers insist and reflects a desire to relieve COs of the burden of performing this analysis when no DoD-appropriated funds are used and when COs have limited ability to evaluate the indirect offset effort in any event.
Contacts
Partner
She/Her/Hers
Insights
Client Alert | 3 min read | 09.17.25
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]
Client Alert | 4 min read | 09.17.25
Client Alert | 5 min read | 09.16.25
Bucking the Odds: Why Technology Companies Should Embrace Software Patents Today
Client Alert | 4 min read | 09.16.25
