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Software Application Insufficient to Substantially Transform Existing Hardware Components Into a Visitor Management System

Client Alert | 1 min read | 05.19.17

In a Final Determination published in the Federal Register today, Customs & Border Protection held that application software installed on existing computers and on an ID scanner manufactured in China did not substantially transform the individual elements (IS scanner, labels, printer and barcode scanner) of the Visitor Management System. The scanners and printers functioned as such when imported, and the software, while defining a specific use, did not change the basic function of the hardware. Although the FAR contemplates that an “end product” offered under a TAA-covered contract should have a single country of origin, the CBP found each element of the VMS retained its individual country of origin, two of which were from China, a non-designated country.

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Client Alert | 5 min read | 12.02.25

CARB Delays Enforcement of California’s Climate-Related Financial Risk Report Law (SB 261) and Issues New Guidance on Climate Disclosure Requirements in SB 261 and SB 253

As we have reported previously, California has enacted a pair of climate-related reporting laws that apply to large entities doing business in California (SB 253 and SB 261, as modified by SB 219). This alert provides an update on only the most recent events; please see previous alerts for a broader overview of the laws’ requirements....