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Sequestration: New Agency Letters Warn Industry

Client Alert | 1 min read | 03.06.13

Federal agencies, including DoD and DHS, began issuing letters to industry this week warning that the effects of sequestration, imposed on March 1, may be felt on existing and planned procurements, may affect agencies' ability to administer contracts efficiently, and in the words of DHS, may result in "existing contracts being reduced in scope, terminated or partially terminated." While asking for industry's cooperation in this time of "enormous budgetary uncertainty" and stating that decisions with respect to specific contracts will be communicated directly by the responsible contracting officials, DoD advised that "damage to the Department and to industry is unfortunately unavoidable at this point."


Insights

Client Alert | 3 min read | 02.11.26

Clicking All the Right Boxes: FTC Moves to Revive “Click-to-Cancel” Rule Following Eighth Circuit Vacatur

On July 8, 2025, the U.S. Court of Appeals for the Eighth Circuit vacated the Federal Trade Commission’s (FTC) Rule Concerning Subscriptions and Other Negative Option Plans, commonly known as the “Click-to-Cancel” rule. As detailed in a previous client alert, the rule was intended to regulate negative option plans[1]— such as subscriptions and automatic renewals — by imposing stringent requirements on businesses, including streamlined cancellation processes and enhanced disclosure obligations. The Eighth Circuit vacated the Click-to-Cancel rule because it found that the FTC had failed to comply with mandatory procedural requirements. As a result, the rule is no longer in effect, and businesses are not currently subject to its mandates....