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Defense Contractors Have Some Leeway to Mark Noncommercial Technical Data to Restrict Rights of Non-Government Third Parties

The U.S. Court of Appeals for the Federal Circuit interprets DFARS technical data rights clause to allow contractors to mark technical data delivered to the government to restrict the rights of non-government third...more

DoD Codifies the NISPOM and Makes Other Changes Regarding Access to Classified Information

The Department of Defense issued a final rule adding the National Industrial Security Program Operating Manual (NISPOM) to the Code of Federal Regulations (CFR) and making other changes relevant to contractors that access...more

Federal Circuit Revives Key Case Addressing Contractor’s Ability to Include Offsets in Measurement of CAS Change Impacts

Case remanded to Court of Federal Claims to clarify whether CAS Impact Calculation involving multiple unilateral changes may include contractor “offsets” Federal Circuit revives the question of whether the FAR 33.606...more

Changes to Small Business Innovation Research Data Rights

Small businesses should prepare for new data rights provisions appearing in Small Business Innovation Research (SBIR) contracts. The Department of Defense (DoD) class deviation addressing SBIR contracts will cause...more

Federal Circuit Decision Addressing Salary Costs Associated with Lobbying Activities Has Broad Implications

On Oct. 18, 2019, the Court of Appeals for the Federal Circuit issued its decision in Raytheon Co. v. Sec. of Def., holding that salary costs associated with lobbying activities are expressly unallowable, and therefore...more

Department of Justice Issues New Guidance on Exemption 4 to the Freedom of Information Act

On Oct. 4, 2019, the DOJ issued guidance for determining whether commercial or financial information provided by a person or company is “confidential” under FOIA Exemption 4. When preparing reverse-FOIA submissions, a...more

Limits on Use of Lowest-Price, Technically Acceptable Procurements at DoD

Department of Defense issues a final rule limiting the ability of defense agencies to use lowest-price, technically acceptable procurement procedures. The new rule takes effect on October 1, 2019 and permits defense...more

Section 809 Panel Recommendations: Overhaul Audit Practices and Increase Reliance on Private-Sector Accounting Rules

This third installment of Pillsbury’s Section 809 alerts focuses on recommendations to modernize and streamline the Department of Defense’s (DoD’s) appropriations, auditing and accounting practices. The Section 809 Panel...more

The Fiscal Year 2019 NDAA Imposes Government-Wide Limitations on the Use of Lowest-Price Technically Acceptable Procurements

Contractors will soon have additional legal authority to demonstrate to civilian agencies that a best value tradeoff process should be employed. Congress’ trend of limiting the use of the LPTA process continues....more

Proposed Rule For Independent Research & Development (“IR&D”) Costs Raises Concerns

On November 4, 2016, the Department of Defense (“DOD”) issued a proposed rule that would amend the Defense Federal Acquisition Regulation Supplement (“DFARS”) to require DOD Contracting Officers to adjust offerors’ proposed...more

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