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  1. To level the playing field for women business owners, the Federal Government limits competition for certain contracts to businesses participating in SBA’s Women-Owned Small Business (“WOSB”) Federal Contracting Program. Ideally, those contracts are for specific industries where WOSBs are historically underrepresented. And in fact, the Government even has certain WOSB contracting goals to encourage such set-asides. So, its easy to see why the WOSB Program can be a great opportunity for small businesses to get a leg up in the federal contracting world. But don’t let the name fool you, it takes more than just woman-ownership to get in–and stay in. Let’s take a closer look at SBA’s requirements for becoming certified under the WOSB Program.

    Under SBA’s WOSB eligibility rules, there are really three main requirements for a company to qualify as a WOSB. The applying (or recertifying) company must: (1) be a small business; (2) with unconditional and direct majority ownership by a woman; and (3) with day-to-day and long-term management by a woman.

    1. Small business.

    First, the company must be a small business under SBA’s size regulations and table of small business size standards. Essentially, the company’s annual receipts averaged over the past five years must not exceed the size standard assigned to the company’s primary North American Industry Classification Systems code.

    2. Unconditional and direct majority woman-ownership.

    Second, the company must be no less than 51% unconditionally and directly owned and controlled by one or more women who are also United States citizens. Easy enough, right? Well, the question that comes up most commonly here is, what do the terms unconditionally and directly really mean. But fortunately for us, SBA’s WOSB ownership regulations elaborate on both.

    Regarding unconditional ownership, they explain that the ownership may “not be subject to any conditions, executory agreements, voting trusts, or other arrangements that cause or potentially cause ownership benefits to go to another.” The regulations clarify that a pledge or encumbrance of stock or other ownership interest as collateral may still qualify “if the terms follow normal commercial practices and the owner retains control absent violations of the terms.” And they add that the percentage of ownership will be determined without regard to community property laws (important for those in community property states).

    Regarding the requirement for direct ownership, the regulations state that the qualifying woman or women (combined) must own at least 51% of the company directly; thus, the 51% ownership cannot be ownership “through another business entity or a trust (including employee stock ownership plan) that is, in turn, owned and controlled by one or more women[.]” But the rules do include the caveat that “ownership by a trust, such as a living trust, may be treated as the functional equivalent of ownership by a woman[] where the trust is revocable, and the woman is the grantor, the trustee, and the sole current beneficiary of the trust.”

    SBA’s ownership regulations then list the various types of companies that the WOSB may be and what is required for woman-ownership in each case. In a nutshell, they explain the following:

    • For Partnership: At least 51% of each class of partnership interest must be unconditionally owned by a woman (or women), and such must be reflected in the partnership agreement (adding that, for purposes of this rule, general and limited partnership interests are to be considered different classes of partnership interest);
    • For LLCs: At least 51% of each class of member interest must be unconditionally owned by a woman (or women); and
    • For Corporations: At least 51% of “each class of voting stock outstanding” and 51% of “the aggregate of all stock outstanding must be unconditionally owned” by a woman (or women), and in determining this, “any unexercised stock options or similar agreements” that are held by a woman (or women) are to be disregarded. But it adds, “any unexercised stock option or other agreement, including the right to convert non-voting stock or debentures into voting stock,” that are held by any other (non-woman) individual or entity are to be treated as having been exercised.

    Finally, the rules also state that the woman-owner(s) must not be suspended or disbarred or have an active exclusion in SAM.Gov at the time of the company’s application or recertification.

    That sums up SBA’s WOSB ownership rules. But apart from popular belief, ownership, on its own, does not demonstrate WOSB control–hence SBA’s separate set of regulations for that requirement.

    3. Day-to-day and long-term management by a woman.

    Third, SBA’s WOSB control regulations explain: “To qualify as a WOSB, the management and daily business operations of the concern must be controlled by one or more women.” According to SBA, woman-control entails “both the long-term decision making and the day-to-day management and administration of the business operations must be conducted by one or more women[.]” But the woman-control requirements don’t end there. In fact, the control requirements seem to be the toughest for applicants and participants to meet and maintain–likely due to the amount of sub-requirements.

    Generally, SBA will look at the company’s organizational documents (i.e. operating agreement or bylaws) to ensure this woman-control requirement is met. SBA will also look at the woman manager’s (or managers’) résumé. Those documents must demonstrate that (1) a woman holds the highest officer position in the company, and that (2) she has the “managerial experience of the extent and complexity needed to run” the company. Often, this can mean having specialized degrees or licenses for certain types of work (i.e. architecture or engineering). Except, the rules do add that the

    woman manager need not have the technical expertise or possess the required license to be found to control the concern if she can demonstrate that she has ultimate managerial and supervisory control over those who possess the required licenses or technical expertise.

    But even then, the rules caution that if any man with an equity interest in the company is the one that possesses this required license, he may be found to control the company, instead.

    The WOSB control rules also limit the woman-manager’s outside employment. They explain that the woman with the highest officer position needs to “manage it on a full-time basis and devote full-time to the business concern during the normal working hours of business concerns in the same or similar line of business.” Indeed, the rules elaborate that the woman-manager “may not engage in outside employment that prevents her from devoting sufficient time and attention to the daily affairs of the concern to control its management and daily business operations.”

    Next, the WOSB control rules (like the WOSB ownership rules did) list the various types of companies that the WOSB may be and what is required for woman-control in each case. In a nutshell, they explain the following:

    • For Partnership: one or more women must serve as general partners, with control over all the partnership’s decisions;
    • For LLCs: one or more women must serve as management members, with control over all the decisions of the LLC; and
    • For Corporations: At least one woman must control the company’s Board of Directors, which means the woman (or women) must either:
      • own at least 51% of all voting stock, be on the Board of Directors, and “have the percentage of voting stock necessary to overcome any super majority voting requirements”; or
      • “comprise the majority of voting directors through actual numbers or, where permitted by state law, through weighted voting.”

    Finally, the control rules address any male involvement head on, stating:

    Men or other entities may be involved in the management of the concern and may be stockholders, partners or limited liability members of the concern. However, no males or other entity may exercise actual control or have the power to control the concern.

    * * *

    Well, there you have it, the basic three requirements for WOSB Program eligibility. But while these rules seem fairly straightforward on paper, they don’t always present easy compliance analyses in reality. And given the significant benefits that participation in SBA’s WOSB Program can bring (including WOSB set-aside competitions and sole source awards)–along with some pretty serious consequences for falsely certifying–it is crucial to understand all of these requirements in full. This is especially true now that the WOSB certification process has become official, now requiring a formal certification by either SBA itself or an SBA-approved third-party certifier.

    Questions about this post, the WOSB Program, or your own eligibility? Email us

    Looking for the latest government contracting legal news? Sign up here for our free monthly newsletter, and follow us on LinkedIn, Twitter and Facebook. 

    The post Back to Basics: WOSB Eligibility first appeared on SmallGovCon - Government Contracts Law Blog.

    View the full article

  2. NITAAC recently announced it obtained 801 certification for fiscal year 2022.  But what exactly is 801 certification and why is it so important? To answer that question, let’s start by looking at the National Defense Authorization Act (NDAA).

    The NDAA is the name for a series of federal laws that determine the annual budget of the U.S. Department of Defense (DoD). The U.S. Congress oversees the defense budget through two yearly bills: the National Defense Authorization Act and defense appropriations bills.

    Within the NDAA is Section 801.  Section 801 provides guidance on the “procurement policies, procedures, and internal controls” that must be followed to assure compliance with defense procurement requirements, particularly for a nondefense agency when it is performing an assisted acquisitions to procure supplies and services on behalf of the DoD.

    More specifically, Section 801 requires that a nondefense agency can only place an order, make a purchase, or procure services on behalf of the DoD if the nondefense agency has been certified and meets all criteria to comply with defense procurement requirements. NITAAC is certified and meets all criteria. 

    The Value of the NITAAC 801 Certification

    NITAAC's recent certification is an important designation as it allows DoD to use NITAAC Assisted Acquisitions Services to place an order, make a purchase, or otherwise procure property or services for the DoD, in excess of the Simplified Acquisition Threshold, without a special waiver. 

    This is particularly beneficial for the DoD as large buys handled by NITAAC assisted acquisitions teams have cycle times that are on average 30-90 days. Additionally, NITAAC only focuses on information technology buys. Many agencies lack in-house information technology expertise and there is now a requirement for contracting professionals who deal predominately in information technology acquisitions to be Digital IT Acquisition Professional (DITAP) certified by 2022 before they are assigned a digital services requirement.

    All NITAAC contracting officers and specialists are DITAP certified, which means they are specially trained to handle information technology procurements. Not only have they completed the rigorous training process, but they are experienced in implementing the most innovative and streamlined strategies in IT procurements.

    Continuing a Long-Standing, Mission-Driven Partnership

    The DoD has turned to NITAAC to support more than $8.7 Billion in acquisitions since its GWAC’s inception. The United States Army, Air Force, the Defense Information Systems Agency (DISA) and the Department of Homeland Security (DHS), to name a few, have long relied on NITAAC to assist with IT modernization, mission analytics and cybersecurity.

    The NITAAC certification ensures that the DoD will benefit from the capabilities and expertise of our contracting officers, as well as the efficiencies and economies associated with leveraging resources and requirements.

    NITAAC is always ready to serve the DoD, so you can keep your focus on your mission. To learn more about NITAAC Assisted Acquisitions Services, call 1-888-773-6542 or visit https://nitaac.nih.gov/services/assisted-acquisitions.

  3. The U.S. Supreme Court slammed the brakes Thursday on a Biden administration vaccine-or-testing rule for private businesses with at least 100 employees, but let a stricter yet narrower rule aimed at the health care industry take effect nationwide.

    Today the Supreme Court of the United States struck down the “OSHA Vax or Test” rule imposed on most employers with over 100 employees stating, “[Congress authorized OSHA] to set workplace safety standards, not broad public health measures.” However, in a separate decision the Court upheld the vaccine mandate for workers at federally funded health care facilities. The Court reasoned “Congress has authorized the Secretary to impose conditions on the receipt of Medicaid and Medicare funds that ‘the Secretary finds necessary in the interest of the health and safety of individuals who are furnished services.’” This authorization permits the strict rules put into place for the covered health care facilities.

    While the two decisions may appear at odds, a common thread can be found. Congress holds the power to authorize the Executive, and its agencies, to create vaccine mandates or related testing requirements. However, Congress must be clear when delegating these powers and for what purpose. Both decisions can be found below, in full.

    https://www.supremecourt.gov/opinions/21pdf/21a240_d18e.pdf
    https://www.supremecourt.gov/opinions/21pdf/21a244_hgci.pdf

    The remaining federal, vaccine mandate is the one applicable to government contractors. That mandate was subject to a nationwide injunction; and, last month, the 11th Circuit Court of Appeals rejected an effort by the U.S. Government to overturn that injunction. Briefing on the merits of the government contractor mandate is not set to be concluded until late February, and oral argument before the 11th Circuit will not be held until early April. With the Supreme Court’s recent rulings, the viability of the government contractor mandate is certainly in question. That said, given the innumerable regulatory requirements already placed on government contractors, the contractor mandate arguably appears more akin to the CMS mandate than the OSHA mandate. Time, and the 11th Circuit, and probably the Supreme Court, will tell.

    Decision Review provided by David Warner, Parter & Tyler Freiberger, Associate Attorney

    The post Breaking Mandate Decisions appeared first on Centre Law & Consulting.

    View the full article

  4. At the beginning of Fiscal Year 2008 John Krieger and John Pritchard, two professors at the Defense Systems Management College, Defense Acquisition University, were kicking around the topic of Acquisition Reform. They reflected on what Jim Nagle wrote in the Epilogue to A History of Government Contracting, "If someone were asked to devise a contracting system for the federal government, it is inconceivable that one reasonable person or a committee of reasonable people could come up with our current system.  That system is the result of thousands of decisions made by thousands of individuals, both in and out of government.  It reflects the collision and collaboration of special interests, the impact of innumerable scandals and successes, and the tensions imposed by conflicting ideologies and personalities."

    They reflected that those thousands of decisions were like putting bandages on the acquisition, contracting and procurement processes.  Every time a piece of legislation is passed to “fix” the acquisition process, it’s another bandage.  Every time a change is made to the Federal Acquisition Regulation (FAR), it’s another bandage.  Every time a change is made to the Defense Federal Acquisition Regulation Supplement (DFARS), it’s another bandage.  Every time a procurement or contracting policy memorandum is issued, it’s another bandage. 

    They joked about that being a great visual aid for the classroom. (Remember classrooms, the places you went to learn before COVID-19?) And the joking became reality. They started with a golf ball, and added a bandage for each new law, executive order, regulation, guide handbook, etc. And it would grow, and grow, and grow. “Acquisition Reform and the Golf Ball” was born that day.

    The story of the golf ball was chronicled each fiscal year, and reported in the National Contract Management Association’s Contract Management (CM) after the end of each fiscal year. That is each year up until the report on the results for Fiscal Year 2020, when CM declined the latest installment in the series. Although John and John sought publication elsewhere, there didn’t appear to be a good fit, which brings the latest iteration, “Acquisition Reform and the Golf Ball—A Baker’s Dozen,” to Wifcon.com. (See attachment.)

    Acquisition_Reform_and_the_Golf_Ball_Bakers_Dozen_-FY2021-_Wifcon.com_v2.docx

  5. Quote

    The blast of flame that sent the black, insect-shaped projectile hurtling across the tarmac made me duck instinctively. It was as if the Devil himself were blasting his way straight from Hell.

    Richard Helms, Director of Central Intelligence, 1966 - 1973

    Many years ago, as a teen, I noticed a magazine on a barbershop table with an incredible black airplane on the cover. Huge engines on each side of a delta wing and a long thin fuselage with a cockpit near the front. I never forgot that airplane, it was an SR-71 Blackbird. Fifty-five years later, I wrote a brief article about the first Blackbird -- the A-12. It's the fastest and highest flying jet airplane that was ever built. Everything about the A-12 was incredible. A requirement was developed to:

    • make an airplane so fast that nothing could catch it,
    • make it fly so high that nothing could reach it, and
    • make it nearly invisible.

    Add to that the fact that no one knew how to do it, the materials didn't exist and it had to be done quickly.  Groom Lake and Area 51 were built for the U-2 and then used for the A-12, Clarence "Kelly" Johnson and his Skunk Works built the U-2 and then built the A-12.  The A-12 was a Central Intelligence Agency (CIA) spy plane just as the U-2 was originally. 

    ----------------------------------------------------

    In September 2020, I finished this 20 page article on the A-12 and placed it on the Analysis Page.  I never thought to post it to the Wifcon Blog.  I'm doing that now.  The article took a long time to write because the building of the A-12 was incredible.  Much of the material used to write this article was from 60 years ago and many potential sources confused the SR-71 story with that of the A-12 story.    Others were flat out wrong.  I used sources from people who worked on or flew the A-12.  Fortunately, the CIA finally declassified some documents on the A-12 sometime after 2000--maybe 2007 or 2013--and made it available to the public.  There wasn't much of it but it filled in some of the missing pieces.

    There are many facts and stories about the A-12 that are of interest.  One is that, in the A-12, the engines produced only about 20 percent of the power at crusing speeds.  Most of the power came from from the pointed cones sticking out of the nacelles.  Also, the A-12 ran its afterburners continuously.  Then there were the 2 Buick "nailhead" V-8s that were conected to each other to "spool-up" and start each A-12 engine.

    At the end of the article, I list the places you can still see an A-12 and added links to Google Maps.  If you look closely at the maps, you will find an image of an A-12.  I also list where the only YF-12A, a derivative of the A-12, is at.  Now, the YF-12A is another story.

    Please read:  Faster Than A Speeding Bullet, Three Times Higher Than The Tallest Mountain.

  6. Robert Marcus, the liquidating trustee of the Las Uvas Valley Dairies sued Dean L. Horton and Frances H. Horton in the U.S. Bankruptcy Court of New Mexico. Mr. Marcus sought declaration that the main assets in the bankruptcy estate at issue were held in constructive trust for the estate he represents. Dean and Frances Horton applied for motion for judgment on the pleadings requesting the proceedings be dismissed for failure to state a claim. Mr. Marcus asserted he had a valid claim for recognition of a constructive trust.

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    View the full article

  7. In the 2019 National Defense Authorization Act (NDAA), Congress placed serious limitations on the Government’s use of Lowest Price, Technically Acceptable (LPTA) procurements. As a result, we should be seeing the Government issue more RFPs in which technology and innovation outweigh price. In these instances, contractors can seek a higher price but are expected to show substantial technological advantages. Two recent protests cases out of GAO illustrate the principles of technical proposal evaluation when technical factors are more important than price, and demonstrate the potential cost/technical trade-offs under these circumstances.

    Read the full article here

  8. ASHBURN, Virginia (September 19, 2018) The National Contract Management Association (NCMA)

    President Charlie Williams Announces the New NCMA Chief Executive Officer

    On behalf of the National Contract Management Association (NCMA) Board of Directors, I am pleased to announce the appointment of Kraig Conrad, CAE, CTP, as the new NCMA Chief Executive Officer. Kraig will formally take his position on November 1, 2018. Kraig joins NCMA with 20 years of association leadership experience. He most recently served as Chief Executive Officer of the Professional Risk Managers’ International Association (PRMIA), where he guided the PRMIA Board of Directors and its global network of more than 50,000 risk professionals to craft an enhanced vision for the group that includes a long-range strategic plan; new advocacy, certification, and training efforts; promoting the PRMIA brand; and enhancing membership benefits.

    Prior to PRMIA, he held many roles at the National Investor Relations Institute, including Acting Co-Chief Executive Office and Vice President for Programs and Development. Kraig has also served as Research Lead for Strategy Practice at Corporate Executive Board, Director of Corporate Finance and Risk Management and Director of Strategic Alliances at the Association for Financial Professionals. He started his career as a Financial Analyst at Credit Suisse.

    Kraig earned a Bachelor of Arts in Economics from the University of Southern California and a Master of Business Administration from the University of Illinois at Chicago. He is a Certified Association Executive and member of the American Society of Association Executives, and a Certified Treasury Professional and member of the Association for Financial Professionals.

    “We are excited to have Kraig join our team. Kraig has demonstrated time and time again exemplary leadership skills and thoughtful approaches to the business of association management,” says NCMA President Charlie Williams. “We are confident that Kraig is the right person at the right time for NCMA as we continue the NCMA journey that was begun over 59 years ago. As our new CEO, Kraig’s association leadership skills will be critical to the Board of Directors as it charts the association’s strategic path forward and seeks to further elevate the association’s relevance to the profession it serves.”

    The selection of Kraig concludes a national search supported by Staffing Advisors, a Washington, DC-based executive search firm. Kraig shares the NCMA dedication to professional growth and the educational advancement of acquisition and contracting professionals worldwide. Please join us in congratulating Kraig as we welcome him to the organization.

    Founded in 1959, the National Contract Management Association (NCMA) is the world's leading professional resource for those in the field of contract management. The organization, which has over 18,000 members, is dedicated to the professional growth and educational advancement of procurement and acquisition personnel worldwide. NCMA strives to serve and inform the profession it represents and to offer opportunities for the open exchange of ideas in neutral forums. For more information on the association, please visit www.ncmahq.org.

    Contact: Amanda Gillespie, Marketing & Communications Director agillespie@ncmahq.org (571) 382-1127

    NCMA_CEO Kraig Conrad - FINAL.pdf

  9. The long-standing principle that the federal government had the same implied duty of good faith and fair dealing as any commercial buyer was put in jeopardy by a 2010 decision of the U.S. Court of Appeals for the Federal Circuit, Precision Pine & Timber, Inc. v. U.S., 596 F.3d 817 (Fed. Cir. 2010). There a panel of the court adopted a narrow rule seemingly limiting application of the principle to situations where a government action was “specifically targeted” at the contractor or had the effect of taking away one of the benefits that had been promised to the contractor. Although the decision concerned a timber sales contract not a procurement contract, when I wrote it up in the May 2010 Nash & Cibinic Report (24 N&CR ¶ 22), I expressed the fear that the reasoning would be subsequently applied to procurement contracts.

    My fear was realized in a construction contract case, Metcalf Construction Co. v. U. S., 102 Fed. Cl. 334 (2011). In that decision, the judge described eggregious conduct on the part of the government officials that would have been held to be a breach of the implied duty of good faith and fair dealing under many earlier cases. However, the judge held that under the Precision Pine standard, the contractor had not proved that the actions were specifically targeted at the contractor. In the February 2012 Nash & Cibinic Report (26 N&CR ¶ 9), I criticized this decision but stated that I believed that even if the decision was affirmed on appeal, most contracting officers would not take this as a signal that the proper way to administer contracts was to abuse the contractor.

    Fortunately, a panel of the Federal Circuit has reversed the decision, Metcalf Construction Co. v. U. S., 2014 WL 519596, 2014 U.S. App. LEXIS 2515 (Fed. Cir. Feb. 11, 2014). The court held that the lower court had read Precision Pine too narrowly and that “specific targeting” was only one example of the type of conduct that could constitute a breach of the implied duty of good faith and fair dealing. Importantly, the court also rejected the government’s argument that this “implied duty” only could be found when it was footed in some express provision of the contract. The court concluded that the correct rule was only that the express provisions of a contract had to be examined to ensure that they had not dealt with the conduct of the government; for if they had, they would override the implied duty.

    This leaves us in a tenuous position with regard to the views of the Federal Circuit. We have one panel in Precision Pine stating a narrow rule, another panel in Metcalf Construction stating the traditional rule, and a third panel in Bell/Heery A Joint Venture v. U.S., 739 F.3d 1324 (Fed. Cir. 2014), ruling in favor of the government because the contractor had not alleged facts showing that the government had “engaged in conduct that reappropriated benefits promised under the contract” (which is part of the Precision Pine reasoning). Thus, it is difficult to state where the judges of the Federal Circuit stand. Hopefully, the court will agree to take either Metcalf Construction or Bell/Heery to the full court for an en banc review of the issue.

    I’ve never been sure why the Department of Justice has so vigorously argued that the government should not be held to the same standards of conduct as a commercial buyer. Of course, persuading the courts and boards that a narrower standard should be applied to the government is a way to win litigated cases. But, in my view, encouraging abusive or non-cooperative conduct hurts the government as much as it hurts its contractors. I have taught for many years that in the long run the government benefits from actions that show industry that it is a fair contracting partner. A line of published judicial decisions that demonstrates that the government is not such a partner is one more of the many messages that tell companies they should sell to the government only when they can find no other customer. Surely, this is not the message that government agencies in need of products and services on the commercial marketplace want to convey to companies that can provide those products and services.

    Many years ago when I came to Washington to work in the field of government contracting, I concluded that there was one major advantage to being on the government side of the negotiating table. That advantage was that I was under no pressure to extract money from the contractor by unfair bargaining or unfair contract administration. To me fairness was an integral part of the job of a government employee. I still believe it and teach it. Thus, no matter what the outcome of the good faith and fair dealing litigation, I will continue to urge government employees that fair treatment of contractors is the only way to go.

    Ralph C. Nash

  10. When I get older, losing my hair

    Many years from now . . . .

    When I'm Sixty-Four

    John Lennon, Paul McCartney

    Shortly after we celebrate our country's independence on July 4, 2013, Wifcon.com will end its 15th year on the internet. With much help from the Wifcon.com community, I've raised a growing teenager. When I started, I was 49 and my hair was so thick that I often shouted ouch or some obscenity when I combed it. Wifcon.com has existed in 3 decades and parts of 2 centuries. During that period, I've updated this site for every work day--except for the week or so when I called it quits. I remember the feeling of relief. I thought it was over. However, many of you convinced me to bring it back. Yes, just when I thought I was out, many of you pulled me back in.

    As I mentioned in an earlier post, someone once told me that Wifcon.com was my legacy. I once had great hopes for a legacy. Perhaps, a great saxophone player belting out a solo in front of thousands of fans and seeing them enjoying themselves. Instead, here I sit in my solitude looking for news, decisions, etc., to post to the home page. For many years, my dog Ambrose kept me company. Now, my dogs Blue Jay and Lily stare at me and look for attention. With my sights now set realistically, I accept that Wifcon.com is my legacy. It's the best I could do.

    Every now and then, I receive an e-mail from someone thanking me for Wifcon.com. They tell me how it helped their careers. These e-mails keep me and Wifcon.com going.

    Send me a postcard, drop me a line,

    Stating point of view

    Indicate precisely what you mean to say

    Yours sincerely, wasting away

    Give me your answer, fill in a form

    When I'm Sixty-Four

    John Lennon, Paul McCartney

    The thoughts in these e-mails won't let me quit. I still search each night for something to add to the site in hopes that it will increase your knowledge. If I find something new, I still get excited. Often, it feels like a self-imposed weight around my neck. What started as a release for my imagination has evolved into a continuing and daily addition to the contracting community. In the evenings, it is as if I'm Maillardet's automaton. I head over to my office, sit before the computer, and update. Then I send the updated pages to Virginia where it is accessed from around the world. Maybe I'm addicted to Wifcon.com; maybe I was born with the Wifcon.com gene.

    If you haven't added the numbers, I'm 64 now. Wifcon.com and I are showing our age. I can comb the top of my head with my fingers. The ouches and other obscenities caused by my once thick hair are gone. A recent upgrade to the discussion forum requires that I turn the "compatibility mode" off on my browser. In that mode, I realized that Wifcon.com is ugly. I have current software for the needed future redo of this site.

    I am Wifcon.com; Wifcon.com is me. It is my legacy and my albatross. As always, thank you for your support.

    You'll be older too,

    And if you say the word,

    I could stay with you.

    When I'm Sixty-Four

    John Lennon, Paul McCartney

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