Wherefore Software In Analyzing Substantial Transformation
Client Alert | 1 min read | 08.10.10
On August 6, 2010, Customs & Border Protection (CBP) published a final determination (75 Fed. Reg. 47609) that Avaya’s Unified Communication Solution was substantially transformed in the United States based upon the totality of the circumstances including installation of the Communication Manager software and the extensive effort at the installation site to integrate the largely foreign hardware components into a working system. CBP rejected Avaya’s assertion that the installation location of software that provides the functionality of a system or hardware could be the sole determinant of substantial transformation under CBP’s prior precedent, as the origin of the software has also been an important factor, and noted here that most of the software development had occurred at Avaya’s Colorado facility, although some ongoing software development now occurs abroad.
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Client Alert | 19 min read | 12.18.25
2025 GAO Bid Protest Annual Report: Where Have All the Protests Gone?
On December 12, 2025, the U.S. Government Accountability Office (GAO) released its annual report on bid protests for fiscal year 2025, containing the full statistics shown below:
Client Alert | 7 min read | 12.17.25
Client Alert | 1 min read | 12.17.25
Client Alert | 7 min read | 12.17.25
Executive Order Tries to Thwart “Onerous” AI State Regulation, Calls for National Framework

