DoD's Proposed Counterfeit Electronic Parts Rules Are Short on Details
Client Alert | 1 min read | 05.22.13
Following up on its publication of an instruction on counterfeit parts on May 16, DoD issued a long-expected proposed rule on counterfeit electronic parts avoidance, detection, and liability, with comments due by July 15. As discussed on our blog, the rule -- which applies only to CAS-covered prime contractors but will have a much broader impact on subcontractors and suppliers -- requires that business systems include DoD-approved avoidance and detection systems, but leaves the details of the newly required systems to be fleshed out, it would seem, by DCAA and/or DCMA, and, while it imposes potentially unlimited liability for counterfeit parts, it has an exceedingly narrow "safe harbor."
Contacts
Insights
Client Alert | 3 min read | 10.24.25
On October 23rd, the U.S. Department of Energy (“DOE”) sent a letter to the Federal Energy Regulatory Commission (“FERC”) containing an Advance Notice of Proposed Rulemaking (“ANOPR”) with principles for all large load interconnections across the US, including those co-located with generating facilities.[1] Significantly, the Secretary of Energy states that the interconnection of large loads to the transmission system “falls squarely” within FERC’s jurisdiction, thus weighing in on a dispute that has been pending before FERC for over a year. This move appears to be a reaction to the continued pendency before FERC of the colocation dockets[2] and a technical conference on colocation held almost a year ago.[3]
Client Alert | 3 min read | 10.24.25
Client Alert | 3 min read | 10.23.25
Are You Ready for the Economic Crime and Corporate Transparency Act? Key Changes for Businesses
Client Alert | 8 min read | 10.23.25
Ransomware on the Rise: The Expanding Role of Legal Counsel in Incident Response
