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Software Application Insufficient to Substantially Transform Existing Hardware Components Into a Visitor Management System

Client Alert | 1 min read | 05.19.17

In a Final Determination published in the Federal Register today, Customs & Border Protection held that application software installed on existing computers and on an ID scanner manufactured in China did not substantially transform the individual elements (IS scanner, labels, printer and barcode scanner) of the Visitor Management System. The scanners and printers functioned as such when imported, and the software, while defining a specific use, did not change the basic function of the hardware. Although the FAR contemplates that an “end product” offered under a TAA-covered contract should have a single country of origin, the CBP found each element of the VMS retained its individual country of origin, two of which were from China, a non-designated country.

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Client Alert | 1 min read | 10.09.25

New California Algorithmic Pricing Law Could Have Far Reaching Effects

This week, California Governor Newsom signed a new California pricing law that will have significant impact to companies doing business in California. The new legislation—known as AB325—will go into effect January 1, 2026 and makes it unlawful under California’s Cartwright Act to collude using a pricing algorithm and to “coerce another person to set or adopt a recommended price or commercial term” using a “common pricing algorithm.”...