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OFCCP Moves To Eliminate Burdensome EO Survey And Offers "Grace Period" For Compliance With Internet Applicant Rule

Client Alert | 1 min read | 01.27.06

On January 20, 2005, the Office of Federal Contract Compliance Programs issued a notice of proposed rulemaking, finally moving to eliminate the burdensome EO Survey -- as the government contracting community has been urging for years. OFCCP is in the process of developing a new system for selecting audit targets.

The OFCCP has also announced that it will not delay implementation of the "Internet Applicant" rule, but will observe a 90-day "grace period." For 90 days following February 6, 2006, OFCCP will not cite a contractor for a purely technical recordkeeping violation for failure to comply with the Internet Applicant final rule, provided that the contractor (1) demonstrates that it is taking reasonable steps to update its systems to comply with the rule, including a projected date of compliance, and (2) collects and maintains records according to the established procedures consistent with OFCCP's recordkeeping requirements that preexisted the Internet Applicant final rule, i.e., 41 CFR 60-1.12.

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Client Alert | 2 min read | 06.15.26

Kansas Federal Court Applies “Selective Enforcement” Theory to Reject DTSA Claim

A Kansas federal court held that inconsistent enforcement of trade secret rights can defeat a claim under the Defend Trade Secrets Act (DTSA). In Edelman Financial Engines, LLC v. Mariner Wealth Advisors LLC, No. 2:23-cv-02515-HLT (D. Kan. June 5, 2026), the court applied a selective enforcement theory, holding that when a company does not consistently pursue legal remedies against similarly situated former employees, that inconsistency can be affirmative evidence that it failed to protect its trade secrets. While the selective enforcement theory has appeared in academic hypothetical discussions, the decision appears to be one of the clearest judicial applications of a “selective enforcement” theory in a trade secret case....

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