Sequestration: The Prequel
Client Alert | 1 min read | 09.26.12
On July 31, 2012, the Defense Procurement and Acquisition Policy (DPAP) office issued a "class deviation" to implement the provisions of section 808 of the 2011 National Defense Authorization Act which prohibit DOD from spending more on contracts for services in 2012 and 2013 than it spent in 2010. The "deviation" requires that CO's set negotiation objectives that do not exceed the labor rates and overhead rates that were in effect during 2010 for the same services, but because the "deviation" also requires that award of any contract that was priced based on rates in excess of those negotiation objectives must be approved by the secretary of the relevant military department or the head of the contracting activity, many DOD CO's are treating the "deviation" as a cap on allowable labor and overhead rates, regardless of any justification that may exist for rate increases.
Insights
Client Alert | 4 min read | 07.02.25
Merger consent orders are back at the FTC, and the FTC’s most recent action showcases how the current leadership is analyzing divestiture proposals. Last week, the FTC approved a proposed consent agreement in Alimentation Couche-Tard Inc.’s (ACT) acquisition of retail fuel outlets from Giant Eagle, Inc. that paired standard retail divestitures with a “prior notice” requirement that ACT notify the agency of future acquisitions in certain markets regardless of size. This FTC has signaled greater acceptance of remedies than the prior administration, and this most recent consent puts that on display, with Commissioner Meador providing merging parties guidance on designing effective remedies.
Client Alert | 3 min read | 07.02.25
USPTO's Upcoming Changes to the Accelerated Examination Program
Client Alert | 2 min read | 07.01.25
DoD Establishes New DOGE Approval Process for ITC&MS and A&AS Contracts
