What The Far Council Giveth The Dar Council Taketh Away
Client Alert | 1 min read | 12.20.06
After several years of consideration, the FAR and DAR Councils published three related sets of regulations in the Federal Register on December 12, 2006, addressing controversial issues about time and material (T&M) and Labor Hour (LH) contracts (see notice on left about upcoming webinar on these regulations). The FAR Council published two final rules permitting competitively awarded contracts for commercial items to qualify as commercial item contracts (with important limitations, including unprecedented rights to interview employees as part of a standard audit) and permitting contractors to bill for work performed by subcontractors on T&M/LH contracts in one of three ways (leaving it to each individual agency to decide which method to permit on the agency’s contracts), while the DAR Council published an interim rule adopting the method of billing subcontractor labor that is likely to be least attractive to industry.
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
