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Relying on a Parent's Experience and Resources in Your Proposal? Some Explanation Required

Client Alert | less than 1 min read | 01.21.16

In Deloitte Consulting, LLP (Nov. 16, 2015), GAO disapproved of the agency crediting a subsidiary with the experience of its corporate parent when the subsidiary's proposal said little more than it receives substantial support from the parent and did not identify which resources and experiences related to which entity. GAO also ruled that, merely because the corporate parent novated to its subsidiary the Federal Supply Schedule contract and blanket purchase agreement under which the contract was awarded, it did not mean that the subsidiary "successor in interest" necessarily had the same resources or experience as its predecessor.

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Client Alert | 3 min read | 07.18.25

Eighth Circuit Cancels Click-to-Cancel

On July 8, 2025, the Eighth Circuit vacated the Federal Trade Commission’s (“FTC”) Negative Option Rule, also known as the Click-to-Cancel Rule, on procedural grounds. The Click-to-Cancel Rule, which provided a streamlined path for consumers to cancel subscription services in a few clicks of a mouse, was scheduled to take effect on July 14, 2025, but the Court found that the FTC had failed to follow mandatory procedural requirements....