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For Whom Does the Appeal Clock Toll? Vitiation vs. Finality

Client Alert | less than 1 min read | 01.12.16

In Guardian Angels Med. Serv. Dogs Inc. v. U.S. (Jan. 8, 2016), the Federal Circuit held that a CO's request to evaluate additional information after a default termination "vitiated the finality" of the termination and reset the 12-month appeal clock, even though the CO neither received new information nor spent any time reconsidering her decision. Reversing the CFC's dismissal of the appeal as time-barred, the court held that, when a CO "evince[s] a clear willingness to consider additional evidence," the appeal period begins anew, rather than merely being suspended, and explained that "whether the contracting officer 'spends time' considering the request is not the proper standard."

Insights

Client Alert | 6 min read | 03.18.26

CFTC Takes Additional Steps Toward Prediction Market Regulation: What You Need to Know

On March 12, 2026, the U.S. Commodity Futures Trading Commission (CFTC) took formal steps toward establishing additional regulations for prediction markets. The agency issued an Advanced Notice of Proposed Rulemaking (ANPRM) soliciting public input on potential new rules, and separately, released staff guidance outlining its views on how existing rules apply to prediction market platforms currently in operation. These developments signal a significant shift in the regulatory landscape for an industry that has grown rapidly over the past year....