No Out-Of-Pockets, No Interest
The Federal Circuit in Richlin Security Serv. Co. v. Certoff (Jan. 31, 2006, http://www.fedcir.gov/opinions/05-1085.pdf) reaffirmed that a contractor can obtain interest on its recovery from the date of the filing of its claim with the contracting officer, even if the amounts recovered had not yet been incurred, as long as the contractor eventually has out-of-pocket expense. This doomed Richlin's interest request, because only the government made out-of-pocket payments for the Service Contract Act deficiencies it claimed.
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