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Raise Confirmed! DoD Finalizes Doubling of CPSR Threshold

Client Alert | 1 min read | 01.10.20

Effective December 31, 2019, the DoD issued a final rule amending the Defense Federal Acquisition Regulation Supplement (DFARS) to establish a DoD contractor purchasing system review (CPSR) threshold of $50M at DFARS 244.302, doubling the existing $25M threshold at FAR 44.302(a). The final rule adopts the proposed rule (discussed here) without any substantive changes. In response to a comment, the final rule clarifies that contractors whose relevant sales have not reached the new threshold may opt to allow their approval to expire rather than incur the costs to maintain a system that meets the criteria for an approved system; in that case, the Government and contractor would continue with consent packages. But, if an approved purchasing system is necessary to support a particular program, the contractor can work with the contracting officer to obtain a CPSR based on risk or pressing need. The final rule also notes that it is a simple increase in the threshold, and does not impact any existing provisions or clauses.

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Client Alert | 3 min read | 06.03.26

Important EU Court Judgment Clarifies Rules on Interest Due in Cartel Damages Cases

In a judgment that will have direct and immediate consequences, the Court of Justice of the European Union (CJEU) has clarified that for all competition damages actions brought after 26 December 2014, interest runs from the date on which the harm occurred. The ruling addressed two important questions: (1) whether national provisions implementing Article 3(2) of the EU Damages Directive — which requires interest to run from the date harm occurred —apply to cases in which the harm preceded the adoption of those provisions; and (2) how the date of harm should be determined in cartel cases involving the purchase of goods at inflated prices....

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