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Many Small Projects Do Not Equal One Big Project

Client Alert | less than 1 min read | 09.28.09

In Caddell Constr. Co. (Sept. 21, 2009), GAO found unreasonable the agency's determination that a vendor had shown the requisite experience performing services "similar in complexity, type of construction, and value to the project being bid" as required by the Security Act in a provision relating to construction of embassies, when the vendor's submission aggregated a number of smaller projects to equal the value of the construction project at issue. Contrary to the agency's determination, GAO held that the statute's experience requirement anticipates that an offeror has completed at least one construction project of similar value and complexity.

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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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