The Gift that Keeps on Giving: FAR Council Attempts to Reduce Burden of Representation Requirement for Covered Telecommunication Offerings
Client Alert | 1 min read | 12.16.19
Following an August 2019 interim rule that implemented a ban on government procurement of any equipment, system, or service that uses covered telecommunications equipment or services (CTES) from certain Chinese companies including Huawei and ZTE, effective December 13, 2019, the FAR Council issued a second interim rule authorizing companies to annually represent whether they provide CTES to the Government in the System for Award Management (SAM) registration. This new provision at FAR 52.204-26 would allow offerors to avoid the offer-by-offer representation requirement in FAR 52.204-24 (currently required under the first interim rule).
FAR 52.204-26 applies to all acquisitions, including simplified and commercial item acquisitions, and requires companies to review SAM and validate whether any products or services originate from CTES prior to completing their required representations. To facilitate compliance, the Government will update SAM to list the Chinese companies that provide CTES and annotate where prohibitions are limited to select products and services instead of the entire company.
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Insights
Client Alert | 4 min read | 12.04.25
District Court Grants Preliminary Injunction Against Seller of Gray Market Snack Food Products
On November 12, 2025, Judge King in the U.S. District Court for the Western District of Washington granted in part Haldiram India Ltd.’s (“Plaintiff” or “Haldiram”) motion for a preliminary injunction against Punjab Trading, Inc. (“Defendant” or “Punjab Trading”), a seller alleged to be importing and distributing gray market snack food products not authorized for sale in the United States. The court found that Haldiram was likely to succeed on the merits of its trademark infringement claim because the products at issue, which were intended for sale in India, were materially different from the versions intended for sale in the U.S., and for this reason were not genuine products when sold in the U.S. Although the court narrowed certain overbroad provisions in the requested order, it ultimately enjoined Punjab Trading from importing, selling, or assisting others in selling the non-genuine Haldiram products in the U.S. market.
Client Alert | 21 min read | 12.04.25
Highlights: CMS’s Proposed Rule for Medicare Part C & D (CY 2027 NPRM)
Client Alert | 11 min read | 12.01.25




