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Final Rule on Supply Chain Risk Fails to Provide Additional Guidance, Protection, or Relief from Uncertain Application

Client Alert | 1 min read | 11.02.15

On October 30, DoD published a final rule (a) requiring evaluation of supply chain risk when acquiring information technology that is either a covered National Security System ("NSS"), part of a covered NSS, or in support of a covered NSS; and (b) authorizing DoD to exclude primes or subs from a particular procurement if they fail to mitigate identified supply chain risks adequately. DoD made relatively modest changes to the 2013 interim rule (e.g., removing the flow-down requirement applicable to subs at any tier) but largely rejected industry input (e.g., declining to identify specific standards or controls to mitigate supply chain risk and declining to create a mechanism for challenging exclusion from a particular source selection).


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Client Alert | 3 min read | 02.11.26

Clicking All the Right Boxes: FTC Moves to Revive “Click-to-Cancel” Rule Following Eighth Circuit Vacatur

On July 8, 2025, the U.S. Court of Appeals for the Eighth Circuit vacated the Federal Trade Commission’s (FTC) Rule Concerning Subscriptions and Other Negative Option Plans, commonly known as the “Click-to-Cancel” rule. As detailed in a previous client alert, the rule was intended to regulate negative option plans[1]— such as subscriptions and automatic renewals — by imposing stringent requirements on businesses, including streamlined cancellation processes and enhanced disclosure obligations. The Eighth Circuit vacated the Click-to-Cancel rule because it found that the FTC had failed to comply with mandatory procedural requirements. As a result, the rule is no longer in effect, and businesses are not currently subject to its mandates....

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