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GAO Blasts FBI's "Second-Tier" IDIQ Solicitations

Client Alert | less than 1 min read | 10.15.15

In Harris IT Servs. Corp. (Oct. 2, 2015), GAO arrested the FBI's issuance of two solicitations under existing IDIQ contracts because each solicitation called for a single, "second-tier IDIQ instrument" that would deny other, existing IDIQ holders the fair opportunity to compete for future task orders as required by FAR 16.505. GAO also found that the contemplated future task orders could potentially exceed the scope of the underlying IDIQ contracts and contained unduly restrictive specifications.


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Client Alert | 5 min read | 06.01.26

California Court Upholds Insurer’s Duty to Defend After Covered Claim Is Dismissed

On April 30, 2026, the U.S. District Court for the Northern District of California issued a significant ruling in an insurance coverage dispute between a commercial general liability insurer and its policyholder. The decision addresses several critical issues in insurance law, including the scope and continuity of the duty to defend and the standard for insurer reimbursement of defense costs in mixed-claim actions. The court ruled largely in favor of the insured, SVO Building One, LLC ("SVO"), and the matter now heads toward settlement or trial on SVO's remaining counterclaims....