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CO Must Identify Extension for Final Decision with Precision

Client Alert | less than 1 min read | 05.27.14

In Suh'dutsing Techs., LLC, the ASBCA held that the contractor could appeal a "deemed denial" of its certified claim 60 days after submission of the claim, notwithstanding the contracting officer's statement that it would be "at least another sixty days . . . before I am able to issue a decision." The Board held the CO's statement was "insufficiently definite" under the Contract Disputes Act, which requires a CO to, within 60 days of receiving a certified claim over $100,000, either issue a decision or "notify the contractor of the time within which a decision will be issued."


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Client Alert | 4 min read | 04.08.26

Cosmetics Under the Microscope: FDA’s Expanding Regulatory Reach Under MoCRA

The Modernization of Cosmetics Regulation Act of 2022 (MoCRA) marked the most significant expansion of FDA’s authority over cosmetics in 80 years — and the agency is putting that authority to work. From the launch of a new adverse event reporting tool to forthcoming rules on fragrance allergens and good manufacturing practices (GMP), FDA is reshaping the regulatory landscape for manufacturers, packers, and distributors of cosmetic and personal care products....