“Did Dawco Constr., Inc. v. United States, 930 F.2d 872 (Fed. Cir. 1991), properly conclude that a Contract Disputes Act (CDA) ‘claim’ as defined in FAR 33.201 requires a pre-existing dispute between a contractor and the government when the claim is in the form of a ‘written assertion … seeking, as a matter of right, the payment of money in a sum certain’ or other contract relief per the first sentence of the FAR definition, or does that requirement only apply when the claim initially is in the form of a ‘routine request for payment?’”
“We hold that sentence of FAR 33.201 sets forth the only three requirements of a non-routine ‘claim’ for money: that it be (1) a written demand, (2) seeking, as a matter of right, (3) the payment of money in a sum certain.”
