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ASBCA Clarifies SOL on Interest Claims Under the Prompt Payment Act

Client Alert | less than 1 min read | 05.23.16

In Public Warehousing Co. (May 2, 2016), the Board held the CDA statute of limitations on a contractor’s claim for interest penalties under the Prompt Payment Act does not accrue until the government makes the underlying payment. Rejecting the government’s argument that the interest claim should accrue as soon as government fails to make the underlying payment, the Board held that, under the PPA, “the events that fix the government's alleged liability and allow a claim for interest penalties to be asserted do not occur until the government pays the underlying invoice without paying the interest penalty due.”

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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....

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