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99x16: Same Particular Matter and 18 U.S.C. § 207(a)(1)

September 10, 1999

A high-level official's attendance at a meeting should be closely reviewed to determine whether his attendance amounts to personal and substantial participation.  Also, an overall acquisition strategy can be an integral part of the contracting process resulting in two separate programs being considered the same particular matter for 18 U.S.C. § 207(a)(1).

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