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 | 4 min read | 05.01.26
Federal Court Blocks Trump Administration Policies Restricting Wind and Solar Permitting
A coalition of regional clean energy trade associations — including RENEW Northeast, Alliance for Clean Energy New York, Southern Renewable Energy Association, and Interwest Energy Alliance — along with the Green Energy Consumers Alliance (GECA), filed suit in December 2025 against the Department of the Interior (DOI), the Bureau of Land Management, the Bureau of Ocean Energy Management, the U.S. Fish and Wildlife Service (USFWS), and the Army Corps of Engineers. The complaint alleged that five agency actions, issued in response to a series of executive orders and presidential memoranda beginning on January 20, 2025, violated the Administrative Procedure Act (APA) by arbitrarily halting or restricting federal permitting for wind and solar energy projects. Plaintiffs sought a preliminary injunction to halt enforcement of these policies while the litigation proceeds. See Renew Northeast, et al. v. U.S. Dep’t of Interior, et al., No. 25-cv-13961-DJC, (D. Mass. Apr. 21, 2026) ECF Dkt. 89.
Client Alert | 8 min read | 05.01.26
Pre-Approved: ICO Publishes Guidance on "Recognised Legitimate Interests”
Client Alert | 6 min read | 04.29.26
CMS Seeks to Expand Interoperability Requirements to Drug Pre-Authorization (FAQ)
Client Alert | 8 min read | 04.27.26
