New Rule Broadens Definition of Human Trafficking and Implements Compliance Obligations
Client Alert | 1 min read | 01.30.15
On January 29, 2015, the FAR Council issued a final rule amending the FAR to reiterate the current, zero-tolerance policy for trafficking in persons, expanding the definition of human trafficking and imposing new obligations on contractors. Please visit our blog here and here for our analysis of the new rule, which includes numerous requirements applicable to all contractors and requires that, for contracts with any portion having an estimated value of over $500,000 for supplies (other than commercially available, off-the-shelf items) acquired, or services performed, overseas, contractors must develop and maintain compliance plans (including procedures for monitoring subcontractors and agents and preventing them from engaging in human trafficking) and certify compliance with the 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.
Client Alert | 21 min read | 12.04.25
Highlights: CMS’s Proposed Rule for Medicare Part C & D (CY 2027 NPRM)
Client Alert | 11 min read | 12.01.25
