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The Pen is Mightier: Typewritten Signature Invalidates CDA Claim

Client Alert | 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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Client Alert | 8 min read | 10.01.25

BIS Issues “Affiliates Rule” to Dramatically Expand Applicability of Entity and Military End-User Lists

On September 29, 2025, the U.S. Department of Commerce Bureau of Industry and Security (BIS) announced a sweeping Interim Final Rule (IFR), (the “Affiliates Rule”) expanding which entities qualify as Entity List or Military End-User entities, thereby subjecting those entities to elevated export control restrictions under the Export Administration Regulations (EAR). U.S. export restrictions applicable to entities on the Entity List, Military End-User (MEU) List, and Specially Designated Nationals and Blocked Persons (SDN List) now apply to foreign affiliates that are, in the aggregate, owned 50% or more by one or more of the aforementioned entities. An entity that becomes subject to these restrictions because of its ownership structure will be subject to the most restrictive controls that attach to any of its parent entities, regardless of ownership stakes....