Contractor’s Role as Prime and Sub Under Same Program Upheld
Client Alert | less than 1 min read | 06.30.15
In Enterprise Info. Servs., Inc. v. DHS (June 16, 2015), the Civilian Board of Contract Appeals ruled that a contractor could perform as both a prime and a subcontractor in different functional categories on the agency's EAGLE II program. The Board rejected DHS's argument that a "news alert" prohibiting that practice acted as a modification and had a legal effect on the prime contract in its current state, but the decision did not foreclose DHS from formally modifying the contract to prohibit the practice.
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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.
Client Alert | 7 min read | 08.19.26
CMS’s Final Rule Bans Federal Medicaid Funding for Youth Gender-Affirming Care
Client Alert | 2 min read | 08.19.26
