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Failure to Consider CAS Materiality Criteria Dooms Gov’t Claim

Client Alert | less than 1 min read | 11.10.16

In Raytheon Co. (ASBCA Aug. 9, 2016), a case involving disallowed cost increases following voluntary accounting changes, the board ruled that the CO violated FAR 30.602 and abused her discretion by considering only the amount of the dollar impact of the accounting changes and, thus, “fail[ed] to analyze the materiality of the cost impacts at issue” pursuant to the criteria set out in CAS 9903.305. Noting (without deciding) that a cost impact of less than 0.005 percent across affected contracts (roughly $142 per contract) might not be “material,” the board held that the government cannot recover on its claim when the CO “simply disregard[s],” rather than evaluates, the CAS materiality factors.

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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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