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For Iraq War Items Sole Source Award, COFC Grants Limited Injunctive Relief Despite OCI And CICA Violations

Client Alert | 1 min read | 05.21.04

In Filtration Dev. Co. LLC v. U.S. (April 27, 2004), the Court of Federal Claims found (1) that a sole source award for filtration kits (to protect helicopters in Iraq from sand damage) that included a directed subcontract violated organizational conflict of interest (OCI) prohibitions because, even though it had performed no work on that system, the subcontractor held a Systems Engineering and Technical Assistance (SETA) contract for the system, and (2) that the urgent and compelling circumstances justification and approval (J&A) for the sole source action, despite explicitly authorizing procurement of a larger number of kits than already ordered by the prime from the designated subcontractor, was limited by the scope of the current emergency to the smaller order already placed. The court granted injunctive relief, but only to preclude further contracts or orders without a new J&A, and declined to enjoin the government from including the directed subcontractor in future competitions or contracting actions because, inter alia, the OCI could be waived.

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Client Alert | 5 min read | 06.11.25

Steel Tariffs Doubled: How the Hike Could Reshape Construction Projects at Home and Abroad

To date the Trump Administration has issued multiple proclamations imposing varying rates of import duties on steel and aluminum and certain derivatives, including construction materials. These measures have added volatility and financial pressures to the construction sector both in the United States and abroad. Most recently, on June 3, 2025, President Donald Trump issued a proclamation under Section 232 of the Trade Expansion Act of 1962, doubling tariffs on imported steel and aluminum from 25% to 50%, effective June 4, 2025. This action aims to counteract the continued influx of lower-priced, excess steel and aluminum imports that, according to the administration, threaten U.S. national security by undermining domestic production capacity. The proclamation notes that while prior tariffs provided some price support, they were insufficient to achieve the necessary capacity utilization rates for sustained industry health and defense readiness. The United Kingdom remains temporarily exempt at the 25% rate until July 9, per the U.S.-U.K. Economic Prosperity Deal....

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