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A GSA Schedule Buy Must Be All Schedule

Client Alert | less than 1 min read | 02.07.05

In KEI Pearson, Inc. (Jan. 10, 2005), the GAO reaffirmed the rule "Non-FSS products may not be purchased using FSS procedures." There, GAO sustained the protest of a GSA schedule procurement because the awardee proposed to acquire certain commercial off-the-shelf software through a lower cost, non-schedule “alliance agreement” between the awardee and the software vendor, rather that proposing to use a more expensive GSA schedule vendor, of which there were many.

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Client Alert | 5 min read | 08.21.26

FTC Proposes Enforcement Policy Statement on Personalized Pricing: What Businesses Need to Know

On August 19, 2026, the Federal Trade Commission (FTC) announced a proposed Enforcement Policy Statement on personalized pricing — the practice of companies using consumers’ personal data to set individualized prices, discounts, coupons, or other incentives. The proposed statement, which is open for public comment for 30 days following publication in the Federal Register, marks a major step up in the FTC’s focus on data-driven pricing strategies and puts businesses across industries on notice that undisclosed or inadequately disclosed personalized pricing will not be tolerated. Importantly, while the proposed statement is not a binding legal requirement and does not create new legal obligations, it serves as an enforcement warning that the FTC is prepared to use its existing enforcement authority under Section 5 of the FTC Act (Section 5) and is also a potential harbinger of rulemaking. Businesses that engage in — or are considering — personalized pricing should carefully assess their disclosure practices and data collection procedures against the standards articulated in this statement....