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25th Anniversary Version Of FMF Guidelines -- No Celebration For It Companies

Client Alert | less than 1 min read | 09.10.09

On August 31, 2009, the Defense Security Cooperation Agency released a revised set of Guidelines for Foreign Military Financing of Direct Commercial Contracts and Contractor's Certification & Agreement with DSCA which are to be implemented no later than October 1, 2009. The principal changes focus on the difficult compliance issue of identifying non-U.S. content in the products and underscore DSCA's increasingly inflexible approach to that issue, including determination whether spares and post-delivery warranty or maintenance effort constitute non-U.S. content ineligible for financing, a problem that has been particularly troubling for companies furnishing information technology products to the Government of Israel under the FMF program.

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Client Alert | 3 min read | 12.13.24

New FTC Telemarketing Sales Rule Amendments

The Federal Trade Commission (“FTC”)  recently announced that it approved final amendments to its Telemarketing Sales Rule (“TSR”), broadening the rule’s coverage to inbound calls for technical support (“Tech Support”) services. For example, if a Tech Support company presents a pop-up alert (such as one that claims consumers’ computers or other devices are infected with malware or other problems) or uses a direct mail solicitation to induce consumers to call about Tech Support services, that conduct would violate the amended TSR. ...