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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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Client Alert | 2 min read | 07.15.26

CMMC Phase II Suspension Requires Reconsideration of Such Requirements in Solicitations

As discussed in more detail here, the U.S. Department of War (DoW) recently issued a memorandum (Memo 26-P-1023, dated July 13, 2026) directing the immediate suspension of Cybersecurity Maturity Model Certification (CMMC) Phase II requirements (Level I and II self assessments are still permitted). Significantly, the memo directs that “all pending and future CMMC implementation milestones across DoW solicitations and contracts are held in abeyance until further notice.” Moreover, the DoW issued a memorandum on implementing these requirements (available here), directing agencies to issue amendments removing CMMC Level 2 and 3 requirements from active solicitations “as soon as practicable.” Contractors should monitor the government’s compliance with this requirement and should be prepared, if needed, to file a bid protest to protect their rights....

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