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Presolicitation Statements Not Dispositive Of Whether Mod Is Beyond Scope

Client Alert | less than 1 min read | 12.28.05

An agency's presolicitation statement that it did not initially intend a contract to include certain work did not bar the agency from later adding that work, according to the Court of Federal Claims in HDM Corp. v. United States (Dec. 14, 2005). Whether a contract was amended beyond its scope depends upon the breadth of the stated objectives of the solicitation, whether bidders were told that work could be added, and the nature of the added work, so early agency statements are not dispositive, the court held in this case successfully litigated by Crowell & Moring.

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Client Alert | 4 min read | 01.07.26

FDA Request for Information Signals New Path for VC Firms and their Portfolio Companies in Federal Contracting

On December 17, 2025, the U.S. Food and Drug Administration (FDA) issued a request for information (RFI) on a proposal designed to help the FDA engage more directly with innovative, venture-backed companies focused on biotechnology, medical devices, AI, and regulatory technology.[i]The RFI includes 19 questions, with responses due by 2:00 p.m. ET on January 18, 2026....