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GSA Seeks Comments on Proposed Class Deviation to Address Open "Recurrent Points of Inconsistency" in Commercial Supplier Agreements

Client Alert | 1 min read | 03.20.15

On March 20, 2015, the General Services Administration published a notice seeking comments on a proposed class deviation to the Federal Acquisition Regulation and General Services Acquisition Regulation intended to address "recurrent points of inconsistency" between Federal law and commercial supplier agreements, to establish that the FAR's commercial item terms take precedence over commercial supplier agreements, and to implement standard terms and conditions in order to minimize the need to individually negotiate agreements. GSA has provided a roadmap to all the terms and conditions customarily used by contractors in commercial supplier agreements (15 in total) that it believes conflict with Federal law; contractors have an opportunity to submit comments on this proposed class deviation on or before April 20, 2015.

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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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