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Profile Picture

Karen L. Manos

Karen
Manos

Partner

CONTACT INFO

kmanos@gibsondunn.com

TEL:+1 202.955.8536

FAX:+1 202.530.9533

Washington, D.C.

1050 Connecticut Avenue, N.W., Washington, DC 20036-5306 USA

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PRACTICE

Government Contracts Aerospace and Related Technologies FCPA FDA and Health Care False Claims Act/Qui Tam Defense Litigation National Security White Collar Defense and Investigations

BIOGRAPHY

Karen L. Manos is a partner in Gibson Dunn’s Washington D.C. office and Chair of the firm’s Government Contracts Practice Group.  Ms. Manos graduated in the top two percent of her class at the U.S. Air Force Academy (B.S., distinguished graduate, 1981), and graduated first in her class from the Duke University School of Law (J.D., with highest honors, 1986), where she was a Note Editor for the Duke Law Journal.  Ms. Manos has nearly thirty years’ experience on a broad range of government contracts issues, including civil and criminal fraud investigations and litigation, complex claims preparation and litigation, bid protests, qui tam suits under the False Claims Act, defective pricing, cost allowability, the Cost Accounting Standards, and corporate compliance programs.

Ms. Manos enjoys a nationwide reputation for her expertise in government contract costs and pricing.  Each year since 2006, Ms. Manos has been selected as one of the leading Government Contracts lawyers in the nation by Chambers USA America’s Leading Business Lawyers, and one of only five lawyers “spotlighted” in the category, Government Contracts: Cost Disputes.  Chambers reported that: “Karen Manos is hailed as the ‘grand queen’ of cost accounting litigation. In addition to her cost accounting expertise her practice spans investigations, claims, bid protests and compliance matters. One client noted: ‘She is, in our view, the best government contract lawyer in the country. She’s brilliant, efficient, and tireless. She’s also a wonderful person.’” One peer remarked, “She is one of the most brilliant cost accounting lawyers I’ve met, and a great theoretician. She is a perfectionist, and she’s very, very good at a very, very difficult area.”  In 2004, Legal Times named Ms. Manos one of the top 12 government contracts lawyers in the Washington, DC area.  In 2009 and 2017, she was nominated by her peers as one of the world’s leading practitioners in the field of public procurement and listed in The International Who’s Who of Public Procurement Lawyers.  In 2010 and 2017, Ms. Manos was selected as one of 10 Washington, DC Super Lawyers in government contracts, and in 2011, Washingtonian Magazine named her a “Star of the Bar” for Government Contracts.  She was named one of the top five “MVPs” in government contracts law for 2012, awarded by Law360 to “attorneys whose achievements in major litigation or transactions have set a new standard for accomplishment in corporate law.”  In 2017 and 2018, Washingtonian Magazine named Ms. Manos as one of Washington’s “Top Lawyers” in Government Contracts.

Ms. Manos is the author of two books:  the three-volume Government Contract Costs & Pricing (Thomson-West 2d ed. 2009), which is widely regarded as the definitive text in the area; and Government Contract Costs & Pricing Handbook (Thomson-West 2012).  In addition, Ms. Manos has authored almost fifty articles on government contract law.  Her publications have appeared in the ABA Public Contract Law Journal, the Catholic University Law Review, Federal Contracts Report, The Government Contractor, the Cost Pricing & Accounting Report, the Nash & Cibinic Report, the Government Contract Audit Report, the Iraq Reconstruction Report, and Purchasing Today.  She has also been quoted in the Wall Street Journal and Washington Business Journal, among other publications.

Ms. Manos previously served as Chair of the American Bar Association Section of Public Contract Law, Chair of the National Defense Industrial Association Procurement Division, and  Editor-in-Chief of the Public Contract Law Journal.  She currently serves as Editor-in-Chief of the Government Contract Accounting, Cost & Pricing Report.

Professional Associations

  • American Bar Association, Section of Public Contract Law: Chair (2009-2010), Chair-Elect (2008-2009), Vice-Chair (2007-2008), Secretary (2006-2007), Council Member (2003-2006), and Co-Chair of the Accounting, Cost & Pricing Committee (2000-2003).
  • National Defense Industrial Association: Chair, Procurement Policy Committee (2009-2011), Vice-Chair, Procurement Policy Committee (2007-2009); Chair, Contract Finance Committee (2004-2006).
  • National Contract Management Association:  Fellow, Certified Professional Contract Manager, and past President of the San Francisco Bay Area Chapter.
  • Public Contract Law Journal Editor-in-Chief
  • Cost, Pricing & Accounting Report Editor-in-Chief
  • The Government Contractor Advisory Board Member
  • Federalist Society Member
  • Martindale-Hubbell AV Preeminent Peer Review Rated

Publications

Books

  • Government Contract Costs & Pricing Handbook (Thomson-West 2012)
  • Government Contract Costs & Pricing (Thomson – West 2d ed. 2009)

Articles

  • “The Most Notable Government Contract Cost And Pricing Decisions Of 2018,” 61 Government Contractor (January 2019).
  • Karen L. Manos, “Lying With Statistics: DCAA’s Misuse Of ‘Statistical’ Sampling To Question Costs By Projection Rather Than Auditing,” Government Contract Costs, Pricing & Accounting Report (July 2017, Vol. 12, Issue 4)
  • “The New Uncompensated Overtime Rule,” 10 Cost, Pricing & Accounting Rep. 13 (March 2015).
  • “Know Your Cost Regulations: The Precontract Cost Principle (FAR 31.205-32),” 8-6 Cost, Pricing & Accounting Report 47 (Nov. 2013).
  • “Penalties for Unallowable Costs,” 8-5 Cost, Pricing & Accounting Report 38 (Sept. 2013).
  • “Records Retention, Untimely Audits and Cost Allowability,” 8-1 Cost, Pricing & Accounting Report 1 (Jan. 2013).
  • Karen L. Manos, Editorial: Federal Circuit Retrospective, 42-1 Pub. Con. L.J. vii (Fall 2012).
  • “The Contract Disputes Act Statute Of Limitations: Take Your Time, DOD,” 6-6 Cost, Pricing & Accounting Report 71 (November 2011).
  • “Special Allocations Under the Cost Accounting Standards,” 6-5 Cost, Pricing & Accounting Report 59 (September 2011).
  • “Know Your Cost Regulations: The Public Relations And Advertising Costs Principle (FAR 31.205-1),” 6-3 Cost, Pricing & Accounting Report 27 (May 2011).
  • “Contractor Business System Audits: The Coming Train Wreck,” 5-6 Cost, Pricing & Accounting Report 1 (Nov. 2010).
  • “Complying With the New Mandatory Disclosure Rule,” 4-1 Cost, Pricing & Accounting Report 1 (Jan. 2009).
  • “Choice of Forum for Government Contract Disputes,” 3-4 Cost, Pricing & Accounting Report 31 (July 2008).
  • “Does the APA Still Apply to Government Contractors?,” 2-5 Costs, Pricing & Accounting Report 44 (Sep. 2007).
  • “Defining Increased Costs in the Aggregate,” 2-2 Costs, Pricing & Accounting  Report 11 (March 2007).
  • “COFC Reconsiders CAS 413 Ruling,” 49-9 Government Contractor 95 (March 2007).
  • “Recovery of Interest Against the Government,” 1-3 Costs, Pricing & Accounting Report  21 (Nov. 2006).
  • “Estoppel Against The Government: What Does “Affirmative Misconduct” Have To Do With It?,” 1-1 Costs, Pricing & Accounting Report  1 (July 2006).
  • “Practitioner’s Comment: Information Systems & Networks Corp.,” Fed. Cir. Nos. 04-5151 & 5154, 48 Government Contractor  61 (2006).
  • “Postscript: Independent Research and Development Costs,” 20 Nash & Cibinic Report  2 (Jan. 2006).
  • “Cherokee Nation: More Than Meets the Eye,” 19 Nash & Cibinic Report  29 (June 2005).
  • “Estimates in Level of Effort Contracts: Wrong Contract Type, Wrong Breach,” 19 Nash & Cibinic Report  23 (May 2005).
  • “Allowability of Legal Costs,” 05-5 Briefing Papers (April 2005).
  • “Defining Cost or Pricing Data,” 47 Government Contractor  192 (2005).
  • “Status of Contractors in Iraq: What Laws Apply?,” Iraq Reconstruction Report (2004).
  • “FAR 31.205-18, Independent Research and Development and Bid and Proposal Costs,” 03-12 Briefing Papers (Nov. 2003).
  • “Caveat Contractor: DCAA’s New Audit Guidance on the Sarbanes-Oxley Act and Contractor Internal Controls,” 80:19 Federal Contracts Report 543 (2003).
  • “The Proposed Rule on Cost Accounting Standards Administration – ‘There You Go Again,'” 45 Government Contractor  302 (2003).
  • “DDP’s Guidance Paper on Changes in Cost Accounting Practice,” 44 Government Contractor  80 (2002).
  • “Practitioner’s Comment: General Dynamics Corp., ASBCA 49372,” 44 Government Contractor  249 (2002).
  • “The Federal Circuit’s Decision in Boeing North American: Better, But Still Wrong,” 44 Government Contractor  203 (2002).
  • “The Non-Appropriated Funds Doctrine: What Do You Mean We Can’t Sue Them?” 6:7 Government Contract Audit Report (2001).
  • “A Critical Analysis of the FAR Council’s New Rule on Labor Relations Costs and Costs Relating to Legal and Other Proceedings,” 75:1 Federal Contracts Report (2001).
  • “Heads We Win, Tails You Lose: The CAS Board’s Remarkable New Proposal on Accounting for the Costs of PRB Plans,” 42 Government Contractor  420 (2000).
  • Co-Author, “Affirmative Action Plans & The “Equal Pay Initiative,” 00-8 Briefing Papers (Aug. 2000).
  • Co-Author, “Pretrial Motions Under the False Claims Act,” 29 Public Contract Law Journal 693 (2000).
  • Co-Author, “A Critical Analysis of the CAS Board’s Proposed Rule on Changes to Cost Accounting Practices,” 41 Government Contractor  402 (1999).
  • “Government Claims to Surplus Pension Assets,” 48 Catholic University Law Review 1139 (1999).
  • “Post-Retirement Benefits: Much Ado About Funding,” 4:5 Government Contract Audit Report (1999).
  • “The Statute of Frauds in Cyberspace,” Purchasing Today (1999).
  • “Allowability of ESOP Interest Costs: DCAA’s Misguided Audit Guidance, 98-6 Costs,” Pricing & Accounting Report (1998).
  • “Legal: To Involve or Not to Involve,” Purchasing Today (1998).
  • “Allowability of Executive Compensation Costs,” 97-13 Briefing Papers (Dec. 1997).
  • Co-Author, “Executive Compensation: A Critical Examination of the Proposed Contract Costs Act of 1997,” 97-3 Costs, Pricing & Accounting Report (1997).
  • “Novation Agreements in Corporate Restructuring: The Government’s Contractual Stealth Weapon,” 26 Public Contract Law Journal 339 (1997).
  • Co-Author, “Special Allocations Under the Cost Accounting Standards,” 96-10 Costs, Pricing & Accounting Report (1996).
  • Co-Author, “Voluntary Accounting Changes Under CAS: A Windfall for the Government?” 25 Public Contract Law Journal 457 (1996).
  • “Protecting Proprietary Information,” 94-13 Briefing Papers (Dec. 1994).
  • “The Antideficiency Act without an ‘M’ Account: Reasserting Constitutional Control,” 23 Public Contract Law Journal 337 (1994).
  • “Recovery of Environmental Costs: A Government Perspective,” 92-8 Costs, Pricing & Accounting Report (1992).
  • Co-Author, Within Cockpit Communications Patterns and Flight Crew Performance, NASA Technical Paper (1982), discussed in 16:11 Psychology Today 42 (1982).

EDUCATION

Duke University - 1986 Juris Doctor

U.S. Air Force Academy - 1981 Bachelor of Science

ADMISSIONS

District of Columbia Bar

North Carolina Bar

RECENT PUBLICATIONS

Client Alert - July 17, 2020 | 2020 Mid-Year False Claims Act Update
Firm News - July 6, 2020 | Gibson Dunn Ranked in 2020 U.S. Legal 500
Client Alert - May 19, 2020 | Aerospace and Related Technologies Update – Spring 2020
Firm News - April 24, 2020 | Gibson Dunn Earns 84 Top-Tier Rankings in Chambers USA 2020
Client Alert - January 31, 2020 | 2019 Year-End False Claims Act Update
Firm News - November 6, 2019 | Who’s Who Legal Practice Guides Recognize Six Gibson Dunn Attorneys in Capital Markets, Government Contracts, and Environment in 2019
Client Alert - July 16, 2019 | 2019 Mid-Year False Claims Act Update
Firm News - July 11, 2019 | Gibson Dunn Ranked in 2019 U.S. Legal 500
Client Alert - March 29, 2019 | Aerospace and Related Technologies Update – Spring 2019
Client Alert - February 14, 2019 | 2018 Year-End Government Contracts Litigation Update
Client Alert - January 10, 2019 | 2018 Year-End False Claims Act Update
Article - January 9, 2019 | The Most Notable Government Contract Cost and Pricing Decisions of 2018
Firm News - November 29, 2018 | Five Gibson Dunn Attorneys Named Among Washingtonian Magazine’s 2018 Top Lawyers
Publications - August 30, 2018 | Webcast: The False Claims Act – 2018 Mid-Year Update: Three Industry-Specific Programs
Publications - August 23, 2018 | Webcast: The False Claims Act – 2018 Mid-Year Update: Drug and Device Industries
Client Alert - July 30, 2018 | 2018 Mid-Year Government Contracts Litigation Update
Client Alert - July 12, 2018 | 2018 Mid-Year False Claims Act Update
Firm News - June 18, 2018 | Gibson Dunn Ranked in 2018 U.S. Legal 500
Firm News - May 9, 2018 | Gibson Dunn Earns 70 Top-Tier Rankings in Chambers USA 2018
Client Alert - March 16, 2018 | Aerospace and Related Technologies – Key Developments in 2017 and Early 2018
Article - January 25, 2018 | The Most Important Government Contract Cost and Pricing Decisions of 2017
Client Alert - January 17, 2018 | 2017 Year-End Government Contracts Update
Client Alert - January 5, 2018 | 2017 Year-End False Claims Act Update
Publications - August 9, 2017 | Webcast: 2017 Mid-Year Update: The False Claims Act and Government Contractors (defense, technology, and others)
Client Alert - July 24, 2017 | 2017 Mid-Year Government Contracts Litigation Update
Article - July 1, 2017 | Lying with Statistics: DCAA’s Misuses of ‘Statistical’ Sampling to Question Costs by Projection Rather Than Auditing
Client Alert - February 2, 2017 | 2016 Year-End Government Contracts Litigation Update
Client Alert - October 31, 2016 | New Cybersecurity Requirements for Defense Contractors Take Effect
Client Alert - August 1, 2016 | 2016 Mid-Year Government Contracts Litigation Update
Article - May 31, 2016 | Know Your Cost Regulations: The Organization Costs Cost Principle
Client Alert - January 19, 2016 | 2015 Year-End Government Contracts Litigation Update
Article - August 5, 2015 | Jurisdictional Issues In Recent Gov’t Contracts Cases: Part 2
Article - August 4, 2015 | Jurisdictional Update On 2015 Gov’t Contracts Cases: Part 1
Client Alert - July 29, 2015 | 2015 Mid-Year Government Contracts Litigation Update
Article - March 16, 2015 | The New Uncompensated Overtime Rule
Client Alert - August 13, 2014 | Sweeping Executive Order Increases Government Contractors’ Labor Law Compliance Burdens
Client Alert - September 1, 2013 | Penalties For Unallowable Costs
Client Alert - January 1, 2013 | Records Retention, Untimely Audits And Cost Allowability
Client Alert - November 1, 2011 | The Contract Disputes Act Statute Of Limitations: Take Your Time, DOD
Client Alert - September 1, 2011 | Special Allocations Under the Cost Accounting Standards
Client Alert - May 24, 2011 | U.S. Department of Defense Issues Interim Rule to Require Withholding of Payments to Contractors with Deficient Business Systems
Client Alert - May 1, 2011 | Know Your Cost Regulations: The Public Relations and Advertising Costs Principal (FAR 31.205-1)
Client Alert - March 30, 2011 | New Law Imposes Excise Tax on U.S. Government Payments to Foreign Entities
Client Alert - December 7, 2010 | U.S. Department of Defense Issues Revised Proposed Rule to Require Withholding of Payments to Contractors with Deficient Business Systems
Client Alert - November 9, 2010 | Contractor Business Systems Audits: The Coming Train Wreck
Client Alert - March 24, 2010 | FAR Councils Issue Final Rule Creating Federal Awardee Performance and Integrity Information System (FAPIIS)
Client Alert - February 24, 2010 | Department of Defense Announces Defense Contract Provisions Prohibiting Contractors’ Use of Arbitration Agreements for Certain Employee Disputes
Client Alert - December 21, 2009 | Proposed Legislation Would Allow Foreign Contractors to Be Sued in U.S. Courts
Client Alert - December 15, 2009 | New Regulations Are Likely on Organizational Conflicts of Interest
Client Alert - October 7, 2009 | Federal Circuit Denies Petition for Rehearing En Banc in Geren v. Tecom, Inc. Upholding the “Very Little Likelihood of Success on the Merits” Standard for Recovering Costs of Defending a Private Employment Discrimination Suit
Client Alert - August 10, 2009 | Labor Department Proposes Rules Requiring Government Contractors to Post Notice of Unionization Rights
Client Alert - June 16, 2009 | Karen Manos Testifies Before the Subcommittee on Government Management, Organization and Procurement
Client Alert - May 27, 2009 | President Obama Signs Law to Reform Pentagon Weapons Spending (P.L. 111-124)
Client Alert - April 6, 2009 | Contractor Business Ethics Compliance Program & Disclosure Requirements
Client Alert - March 26, 2009 | President Obama Directs Additional Restrictions on Spending of Recovery Act Funds and Lobbying Communications Concerning the Expenditure of Such Funds and Related Policies
Client Alert - March 5, 2009 | Obama Administration Undertakes Review of Procurement Law
Client Alert - February 2, 2009 | Three Executive Orders Signed Friday Increase Employment Requirements on Federal Contractors
Client Alert - January 5, 2009 | Delay in Implementing Certain Aspects of the U.S.-Iraq SOFA against U.S. Contractors
Client Alert - January 1, 2009 | Complying With The New Mandatory Disclosure Rule
Client Alert - December 1, 2008 | New Status of Forces Agreement Subjects Government Contractors to Iraqi Law
Client Alert - July 1, 2008 | Choice of Forum for Government Contract Disputes
Client Alert - May 9, 2008 | ITAR Update: Technical Data Found on the Internet May Not Be Considered in the Public Domain
Client Alert - September 1, 2007 | Does The APA Still Apply To Government Contractors?
Client Alert - March 30, 2007 | Cost & Pricing Issues
Client Alert - March 15, 2007 | Defining “Increased Costs in the Aggregate”
Client Alert - March 7, 2007 | COFC Reconsiders CAS 413 Ruling
Client Alert - February 5, 2007 | Rule Change Significantly Alters Civil Settlement Negotiation Environment; Permits Government to Use Civil Settlement Statements in Criminal Prosecutions
Client Alert - January 19, 2007 | Fourth Circuit Holds Employer Health-Coverage Mandates Are Preempted, Strikes Down Maryland’s “Anti-Wal-Mart Law”
Client Alert - January 18, 2007 | Congress Proposes Legislation to Criminalize War Profiteering
Client Alert - November 1, 2006 | Recovery of Interest Against the Government
Client Alert - October 13, 2006 | Department of Justice Establishes New Task Force to Combat Fraud In Government Contracting
Client Alert - August 14, 2006 | Department of Defense Proposed Rule Highlights Need for Effective Export Compliance Program
Client Alert - July 18, 2006 | Estoppel Against The Government: What Does ‘Affirmative Misconduct’ Have To Do With It?
Client Alert - February 22, 2006 | Shareholder Taxes On Dividends Are Not Allowable Costs For Subchapter S Corporation, Federal Circuit Holds
Client Alert - February 1, 2006 | Cost and Pricing Issues – West Government Contracts Year in Review Conference
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