The Pen is Mightier: Typewritten Signature Invalidates CDA Claim
Client Alert | less than 1 min read | 01.05.17
In ABS Development Corp. (ASBCA Nov. 17, 2016), the Board dismissed for lack of jurisdiction certain contractor claims that had been “certified” by means of typewritten names in signature-font (rather than the acceptable handwritten or e-signatures) because a typewritten name “cannot be authenticated, and, therefore, is not a signature.” Because the CDA’s purpose is to bind contractors by means of a signed certificate that “cannot be easily disavowed by the purported author,” the Board held that typed signatures were jurisdictionally inadequate and could not be cured (via a substitute signature), a reminder to contractors that a critical element of litigating CDA claims is adherence to statutory requirements as well as the Board’s rules.
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The U.S. Government Accountability Office’s (GAO) recent decision in Viderity Inc.—Costs, B-424422.5, Sept. 1, 2026, offers useful insight into what constitutes a legally sufficient conflict of interest investigation. The decision arose in an unusual procedural posture: Viderity initially protested, alleging that an agency evaluator had a personal conflict of interest. After the agency took corrective action, Viderity filed a cost entitlement claim requesting that GAO direct the agency to reimburse Viderity’s protest costs. In evaluating that claim, GAO assessed whether Viderity’s underlying protest ground was “clearly meritorious.”
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