Cravath Publishes Winter 2026 Issue of Alumni Journal
Scott Bennett focuses his practice on venture capital and growth equity transactions, IPOs and other capital markets transactions, public company representations and other corporate matters. He is Co‑Head of the Venture Capital & Growth Equity Practice and Co‑Head of the Digital Assets Practice.
He is a leading practitioner in the technology, fintech, digital assets and artificial intelligence spaces. He has also counseled numerous clients in the consumer, energy, energy transition, life sciences, shipping and transportation sectors.
Notable work highlights include:
- IPOs, direct listings, spin-offs and de-SPAC transactions for companies such as Alcon, AOL, Bitdeer, BitGo, Costamare Bulkers, Galaxy Digital, GasLog Partners, Global Brass and Copper, GrafTech International, Jose Cuervo, Radius Global Infrastructure, Robinhood and Symetra Financial
- Company-side venture financings such as Quibi’s $750 million Series C financing and Robinhood’s $3.4 billion private placement of convertible notes and warrants, and venture investments by Brevan Howard Digital, Bristol Myers Squibb, D.E. Shaw, Paradigm and Thrive Capital
- Representations in the blockchain and digital assets space, including Bitdeer on SEC issues related to its de‑SPAC transaction, Brevan Howard in its investment in Ripple, Circle on regulatory matters related to its IPO, Robinhood in its IPO, Silvergate Bank in its wind‑down of operations and chapter 11 bankruptcy, Art Blocks in connection with a venture financing round, the underwriters in BitGo’s IPO and the underwriters in the first U.S. public offering by Galaxy Digital
- Other equity and debt offerings for companies such as Alcoa, Alcon, Cencora, Cornerstone Chemical, Costamare, Entegris, Galaxy Digital, GasLog, GasLog Partners, Hain Celestial, Hess Midstream, Leidos, Marathon Oil, Marathon Petroleum, MPLX, Phillips 66, Qualcomm, Sherwin‑Williams and Weyerhaeuser
- Mergers and acquisitions transactions such as GasLog’s take‑private transaction with BlackRock’s Global Energy & Power Infrastructure Fund and its subsequent acquisition of GasLog Partners and Star Bulk’s $2.1 billion combination with Eagle Bulk Shipping
Mr. Bennett is a frequent speaker and author on a range of legal topics pertaining to finance, capital markets, venture capital and emerging companies, as well as developments in the areas of fintech and digital assets.
Mr. Bennett was named a “Dealmaker of the Year” by The American Lawyer, “Lawyer of the Year” for Corporate Law by The Best Lawyers in America and a “Rising Star” by Law360. He has been repeatedly recognized for his work in the capital markets arena by The Legal 500 US, The Legal 500 Latin America and IFLR1000, among others. Additionally, Mr. Bennett has been recognized for his work in the fintech sector by The Legal 500 US and his work in corporate law by The Best Lawyers in America, and he has been named one of the “500 Leading Dealmakers in America” by Lawdragon.
Mr. Bennett was born in Sarasota, Florida. He received a B.A. in Economics from Duke University in 2002. Mr. Bennett received a J.D. with High Honors from Emory University School of Law in 2006, where he was the First Honor Graduate (i.e., valedictorian) and a member of the Law Journal.
Mr. Bennett joined Cravath in 2006 and was elected a partner in 2013.
He is a leading practitioner in the technology, fintech, digital assets and artificial intelligence spaces. He has also counseled numerous clients in the consumer, energy, energy transition, life sciences, shipping and transportation sectors.
Notable work highlights include:
- IPOs, direct listings, spin-offs and de-SPAC transactions for companies such as Alcon, AOL, Bitdeer, BitGo, Costamare Bulkers, Galaxy Digital, GasLog Partners, Global Brass and Copper, GrafTech International, Jose Cuervo, Radius Global Infrastructure, Robinhood and Symetra Financial
- Company-side venture financings such as Quibi’s $750 million Series C financing and Robinhood’s $3.4 billion private placement of convertible notes and warrants, and venture investments by Brevan Howard Digital, Bristol Myers Squibb, D.E. Shaw, Paradigm and Thrive Capital
- Representations in the blockchain and digital assets space, including Bitdeer on SEC issues related to its de‑SPAC transaction, Brevan Howard in its investment in Ripple, Circle on regulatory matters related to its IPO, Robinhood in its IPO, Silvergate Bank in its wind‑down of operations and chapter 11 bankruptcy, Art Blocks in connection with a venture financing round, the underwriters in BitGo’s IPO and the underwriters in the first U.S. public offering by Galaxy Digital
- Other equity and debt offerings for companies such as Alcoa, Alcon, Cencora, Cornerstone Chemical, Costamare, Entegris, Galaxy Digital, GasLog, GasLog Partners, Hain Celestial, Hess Midstream, Leidos, Marathon Oil, Marathon Petroleum, MPLX, Phillips 66, Qualcomm, Sherwin‑Williams and Weyerhaeuser
- Mergers and acquisitions transactions such as GasLog’s take‑private transaction with BlackRock’s Global Energy & Power Infrastructure Fund and its subsequent acquisition of GasLog Partners and Star Bulk’s $2.1 billion combination with Eagle Bulk Shipping
Mr. Bennett is a frequent speaker and author on a range of legal topics pertaining to finance, capital markets, venture capital and emerging companies, as well as developments in the areas of fintech and digital assets.
Mr. Bennett was named a “Dealmaker of the Year” by The American Lawyer, “Lawyer of the Year” for Corporate Law by The Best Lawyers in America and a “Rising Star” by Law360. He has been repeatedly recognized for his work in the capital markets arena by The Legal 500 US, The Legal 500 Latin America and IFLR1000, among others. Additionally, Mr. Bennett has been recognized for his work in the fintech sector by The Legal 500 US and his work in corporate law by The Best Lawyers in America, and he has been named one of the “500 Leading Dealmakers in America” by Lawdragon.
Mr. Bennett was born in Sarasota, Florida. He received a B.A. in Economics from Duke University in 2002. Mr. Bennett received a J.D. with High Honors from Emory University School of Law in 2006, where he was the First Honor Graduate (i.e., valedictorian) and a member of the Law Journal.
Mr. Bennett joined Cravath in 2006 and was elected a partner in 2013.
Education
-
J.D., 2006, Emory University School of Law
-
B.A., 2002, Duke University
Admitted In
- New York
Rankings
The American Lawyer
- Dealmaker of the Year (2020)
Best Lawyers in America
- Corporate Law (2026-2022)
- Corporate Law: Lawyer of the Year – New York City (2025)
IFLR1000
- Banking - US (2025‑2016)
- Capital Markets - US (2025‑2016)
Law360
- Rising Star: Capital Markets (2018)
Lawdragon
- 500 Leading Dealmakers in America (2025-2021)
The Legal 500 Latin America
- Capital Markets – Latin America: International Firms (2017, 2016, 2015)
- Corporate and M&A – Latin America: International Firms (2017, 2016)
The Legal 500 US
- Capital Markets: Debt Offerings (2024-2020, 2016, 2014)
- Capital Markets: Equity Offerings (2025-2017, 2015, 2014)
- Capital Markets: Global Offerings (2022-2017, 2014)
- Capital Markets: High‑Yield Debt Offerings (2024, 2023, 2015)
- Fintech (2025-2019)
- Technology Transactions (2016)
- Telecoms and Broadcast: Transactions (2018)
Super Lawyers ‑ Rising Stars ‑ New York
- Securities & Corporate Finance (2017, 2016)
Deals & Cases
February 26, 2026
MPLX LP’s $1.5 Billion Registered Senior Notes Offering
Cravath represented the underwriters in connection with the $1.5 billion registered senior notes offering of MPLX LP, a master limited partnership formed by Marathon Petroleum Corporation. MPLX LP owns, operates, develops and acquires pipelines and other midstream assets related to the transportation and storage of crude oil, refined products and other hydrocarbon-based products. The transaction closed on February 12, 2026.
Deals & Cases
January 23, 2026
BitGo’s IPO
Cravath represented the underwriters in connection with the $212.8 million initial public offering of class A common stock of BitGo Holdings, Inc. (“BitGo”), a leading infrastructure provider of digital asset solutions for businesses, offering solutions including custody, wallets, staking, trading, settlement and digital asset management. The shares were listed on the New York Stock Exchange. The transaction closed on January 23, 2026.
Deals & Cases
November 18, 2025
Ripple Labs, Inc.’s Private Placement of Class A Common Stock
Cravath represented funds managed by affiliates of Brevan Howard in connection with an investment in Ripple Labs, Inc., consisting of a private placement of Class A Common Stock, as part of Ripple’s $500 million strategic investment at a $40 billion valuation, led by funds managed by affiliates of Fortress Investment Group, affiliates of Citadel Securities, Pantera Capital, Galaxy Digital, Brevan Howard and Marshall Wace. The transaction closed on November 4, 2025.
Deals & Cases
October 02, 2025
Phillips 66 Company’s $2 Billion Registered Junior Subordinated Notes Offering
Cravath represented the underwriters in connection with the $2 billion registered junior subordinated notes offering of Phillips 66 Company, guaranteed by Phillips 66, an energy manufacturing and logistics company with midstream, chemicals, refining, marketing and specialties businesses. The transaction closed on September 18, 2025.
Deals & Cases
August 25, 2025
MPLX LP’s $4.5 Billion Registered Senior Notes Offering
Cravath represented the underwriters in connection with the $4.5 billion registered senior notes offering of MPLX LP, a master limited partnership formed by Marathon Petroleum Corporation. MPLX LP owns, operates, develops and acquires pipelines and other midstream assets related to the transportation and storage of crude oil, refined products and other hydrocarbon-based products. The transaction closed on August 11, 2025.
Activities
February 27, 2026
John White, Scott Bennett and Justin Clarke Participate in the 42nd Annual Federal Securities Institute and M&A Conference
From February 26-27, Cravath partners John W. White, D. Scott Bennett and Justin C. Clarke participated in the Florida Bar’s 42nd Annual Federal Securities Institute and M&A Conference in Tampa, Florida. John moderated a panel entitled “Evolving Accounting and Auditing Focal Points in 2026,” which discussed best practices for interacting with the SEC staff, what lies ahead at the SEC, what’s new from FASB and the PCAOB’s new priorities and leadership. Scott moderated a panel entitled “Recent Developments in Digital Assets and Tokenization,” which explored the impact of tokenization, ETFs and digital asset treasury companies, new crypto legislation and what lies ahead. Justin moderated a panel entitled “Private Securities Litigation – 2025 Developments and Trends,” which analyzed trends in securities class action filings, case law updates and new and developing issues.
Publications
February 13, 2026
Cravath Venture Capital & Growth Equity Insights: 2025 Recap and 2026 Outlook
On February 13, 2026, Cravath published the latest edition of its Venture Capital & Growth Equity Insights newsletter, which provides insight into global venture capital and related activity during 2025 and an outlook for the coming year. Key takeaways from this edition include:
Activities
February 13, 2026
Scott Bennett, Elad Roisman, Nick Dorsey and Sasha Rosenthal‑Larrea Featured in Lawdragon’s “Lawyer Limelight” Series
On February 12, 2026, Cravath partners D. Scott Bennett, Elad Roisman, Nicholas A. Dorsey and Sasha Rosenthal‑Larrea were profiled in Lawdragon’s “Lawyer Limelight” series in connection with the Firm’s work for “companies at the forefront of innovation in digital assets, AI, fintech, biotech, media and emerging technologies.”
Activities
February 13, 2026
Scott Bennett Moderates “Legal as a Strategic Partner: Best Practices for Contracts and Product‑Related Matters” Roundtable at The L Suite’s GC Dinner
On February 12, 2026, Cravath partner D. Scott Bennett participated in The L Suite’s General Counsel Roundtable Dinner in New York. Scott moderated a discussion between chief legal officers and general counsels at high‑growth tech companies and venture funds on the topic “Legal as a Strategic Partner: Best Practices for Contracts and Product‑Related Matters.”
Publications
December 29, 2025
Section 16(a) Share Ownership and Transaction Reporting Obligations to Apply to Directors and Officers of Foreign Private Issuers from March 18, 2026
On December 23, 2025, Cravath prepared a memo for its clients entitled “Section 16(a) Share Ownership and Transaction Reporting Obligations to Apply to Directors and Officers of Foreign Private Issuers from March 18, 2026.” The memo examines the Holding Foreign Insiders Accountable Act and how directors and officers of foreign private issuers will be required to comply with the share ownership and transaction reporting obligations of paragraph (a) of Section 16 of the Securities Exchange Act of 1934 within 90 days of the enactment of the 2026 U.S. National Defense Authorization Act.
Scott Bennett focuses his practice on venture capital and growth equity transactions, IPOs and other capital markets transactions, public company representations and other corporate matters. He is Co‑Head of the Venture Capital & Growth Equity Practice and Co‑Head of the Digital Assets Practice.
He is a leading practitioner in the technology, fintech, digital assets and artificial intelligence spaces. He has also counseled numerous clients in the consumer, energy, energy transition, life sciences, shipping and transportation sectors.
Notable work highlights include:
- IPOs, direct listings, spin-offs and de-SPAC transactions for companies such as Alcon, AOL, Bitdeer, BitGo, Costamare Bulkers, Galaxy Digital, GasLog Partners, Global Brass and Copper, GrafTech International, Jose Cuervo, Radius Global Infrastructure, Robinhood and Symetra Financial
- Company-side venture financings such as Quibi’s $750 million Series C financing and Robinhood’s $3.4 billion private placement of convertible notes and warrants, and venture investments by Brevan Howard Digital, Bristol Myers Squibb, D.E. Shaw, Paradigm and Thrive Capital
- Representations in the blockchain and digital assets space, including Bitdeer on SEC issues related to its de‑SPAC transaction, Brevan Howard in its investment in Ripple, Circle on regulatory matters related to its IPO, Robinhood in its IPO, Silvergate Bank in its wind‑down of operations and chapter 11 bankruptcy, Art Blocks in connection with a venture financing round, the underwriters in BitGo’s IPO and the underwriters in the first U.S. public offering by Galaxy Digital
- Other equity and debt offerings for companies such as Alcoa, Alcon, Cencora, Cornerstone Chemical, Costamare, Entegris, Galaxy Digital, GasLog, GasLog Partners, Hain Celestial, Hess Midstream, Leidos, Marathon Oil, Marathon Petroleum, MPLX, Phillips 66, Qualcomm, Sherwin‑Williams and Weyerhaeuser
- Mergers and acquisitions transactions such as GasLog’s take‑private transaction with BlackRock’s Global Energy & Power Infrastructure Fund and its subsequent acquisition of GasLog Partners and Star Bulk’s $2.1 billion combination with Eagle Bulk Shipping
Mr. Bennett is a frequent speaker and author on a range of legal topics pertaining to finance, capital markets, venture capital and emerging companies, as well as developments in the areas of fintech and digital assets.
Mr. Bennett was named a “Dealmaker of the Year” by The American Lawyer, “Lawyer of the Year” for Corporate Law by The Best Lawyers in America and a “Rising Star” by Law360. He has been repeatedly recognized for his work in the capital markets arena by The Legal 500 US, The Legal 500 Latin America and IFLR1000, among others. Additionally, Mr. Bennett has been recognized for his work in the fintech sector by The Legal 500 US and his work in corporate law by The Best Lawyers in America, and he has been named one of the “500 Leading Dealmakers in America” by Lawdragon.
Mr. Bennett was born in Sarasota, Florida. He received a B.A. in Economics from Duke University in 2002. Mr. Bennett received a J.D. with High Honors from Emory University School of Law in 2006, where he was the First Honor Graduate (i.e., valedictorian) and a member of the Law Journal.
Mr. Bennett joined Cravath in 2006 and was elected a partner in 2013.
He is a leading practitioner in the technology, fintech, digital assets and artificial intelligence spaces. He has also counseled numerous clients in the consumer, energy, energy transition, life sciences, shipping and transportation sectors.
Notable work highlights include:
- IPOs, direct listings, spin-offs and de-SPAC transactions for companies such as Alcon, AOL, Bitdeer, BitGo, Costamare Bulkers, Galaxy Digital, GasLog Partners, Global Brass and Copper, GrafTech International, Jose Cuervo, Radius Global Infrastructure, Robinhood and Symetra Financial
- Company-side venture financings such as Quibi’s $750 million Series C financing and Robinhood’s $3.4 billion private placement of convertible notes and warrants, and venture investments by Brevan Howard Digital, Bristol Myers Squibb, D.E. Shaw, Paradigm and Thrive Capital
- Representations in the blockchain and digital assets space, including Bitdeer on SEC issues related to its de‑SPAC transaction, Brevan Howard in its investment in Ripple, Circle on regulatory matters related to its IPO, Robinhood in its IPO, Silvergate Bank in its wind‑down of operations and chapter 11 bankruptcy, Art Blocks in connection with a venture financing round, the underwriters in BitGo’s IPO and the underwriters in the first U.S. public offering by Galaxy Digital
- Other equity and debt offerings for companies such as Alcoa, Alcon, Cencora, Cornerstone Chemical, Costamare, Entegris, Galaxy Digital, GasLog, GasLog Partners, Hain Celestial, Hess Midstream, Leidos, Marathon Oil, Marathon Petroleum, MPLX, Phillips 66, Qualcomm, Sherwin‑Williams and Weyerhaeuser
- Mergers and acquisitions transactions such as GasLog’s take‑private transaction with BlackRock’s Global Energy & Power Infrastructure Fund and its subsequent acquisition of GasLog Partners and Star Bulk’s $2.1 billion combination with Eagle Bulk Shipping
Mr. Bennett is a frequent speaker and author on a range of legal topics pertaining to finance, capital markets, venture capital and emerging companies, as well as developments in the areas of fintech and digital assets.
Mr. Bennett was named a “Dealmaker of the Year” by The American Lawyer, “Lawyer of the Year” for Corporate Law by The Best Lawyers in America and a “Rising Star” by Law360. He has been repeatedly recognized for his work in the capital markets arena by The Legal 500 US, The Legal 500 Latin America and IFLR1000, among others. Additionally, Mr. Bennett has been recognized for his work in the fintech sector by The Legal 500 US and his work in corporate law by The Best Lawyers in America, and he has been named one of the “500 Leading Dealmakers in America” by Lawdragon.
Mr. Bennett was born in Sarasota, Florida. He received a B.A. in Economics from Duke University in 2002. Mr. Bennett received a J.D. with High Honors from Emory University School of Law in 2006, where he was the First Honor Graduate (i.e., valedictorian) and a member of the Law Journal.
Mr. Bennett joined Cravath in 2006 and was elected a partner in 2013.
Education
-
J.D., 2006, Emory University School of Law
-
B.A., 2002, Duke University
Admitted In
- New York
Rankings
The American Lawyer
- Dealmaker of the Year (2020)
Best Lawyers in America
- Corporate Law (2026-2022)
- Corporate Law: Lawyer of the Year – New York City (2025)
IFLR1000
- Banking - US (2025‑2016)
- Capital Markets - US (2025‑2016)
Law360
- Rising Star: Capital Markets (2018)
Lawdragon
- 500 Leading Dealmakers in America (2025-2021)
The Legal 500 Latin America
- Capital Markets – Latin America: International Firms (2017, 2016, 2015)
- Corporate and M&A – Latin America: International Firms (2017, 2016)
The Legal 500 US
- Capital Markets: Debt Offerings (2024-2020, 2016, 2014)
- Capital Markets: Equity Offerings (2025-2017, 2015, 2014)
- Capital Markets: Global Offerings (2022-2017, 2014)
- Capital Markets: High‑Yield Debt Offerings (2024, 2023, 2015)
- Fintech (2025-2019)
- Technology Transactions (2016)
- Telecoms and Broadcast: Transactions (2018)
Super Lawyers ‑ Rising Stars ‑ New York
- Securities & Corporate Finance (2017, 2016)
Deals & Cases
February 26, 2026
MPLX LP’s $1.5 Billion Registered Senior Notes Offering
Cravath represented the underwriters in connection with the $1.5 billion registered senior notes offering of MPLX LP, a master limited partnership formed by Marathon Petroleum Corporation. MPLX LP owns, operates, develops and acquires pipelines and other midstream assets related to the transportation and storage of crude oil, refined products and other hydrocarbon-based products. The transaction closed on February 12, 2026.
Deals & Cases
January 23, 2026
BitGo’s IPO
Cravath represented the underwriters in connection with the $212.8 million initial public offering of class A common stock of BitGo Holdings, Inc. (“BitGo”), a leading infrastructure provider of digital asset solutions for businesses, offering solutions including custody, wallets, staking, trading, settlement and digital asset management. The shares were listed on the New York Stock Exchange. The transaction closed on January 23, 2026.
Deals & Cases
November 18, 2025
Ripple Labs, Inc.’s Private Placement of Class A Common Stock
Cravath represented funds managed by affiliates of Brevan Howard in connection with an investment in Ripple Labs, Inc., consisting of a private placement of Class A Common Stock, as part of Ripple’s $500 million strategic investment at a $40 billion valuation, led by funds managed by affiliates of Fortress Investment Group, affiliates of Citadel Securities, Pantera Capital, Galaxy Digital, Brevan Howard and Marshall Wace. The transaction closed on November 4, 2025.
Deals & Cases
October 02, 2025
Phillips 66 Company’s $2 Billion Registered Junior Subordinated Notes Offering
Cravath represented the underwriters in connection with the $2 billion registered junior subordinated notes offering of Phillips 66 Company, guaranteed by Phillips 66, an energy manufacturing and logistics company with midstream, chemicals, refining, marketing and specialties businesses. The transaction closed on September 18, 2025.
Deals & Cases
August 25, 2025
MPLX LP’s $4.5 Billion Registered Senior Notes Offering
Cravath represented the underwriters in connection with the $4.5 billion registered senior notes offering of MPLX LP, a master limited partnership formed by Marathon Petroleum Corporation. MPLX LP owns, operates, develops and acquires pipelines and other midstream assets related to the transportation and storage of crude oil, refined products and other hydrocarbon-based products. The transaction closed on August 11, 2025.
Activities
February 27, 2026
John White, Scott Bennett and Justin Clarke Participate in the 42nd Annual Federal Securities Institute and M&A Conference
From February 26-27, Cravath partners John W. White, D. Scott Bennett and Justin C. Clarke participated in the Florida Bar’s 42nd Annual Federal Securities Institute and M&A Conference in Tampa, Florida. John moderated a panel entitled “Evolving Accounting and Auditing Focal Points in 2026,” which discussed best practices for interacting with the SEC staff, what lies ahead at the SEC, what’s new from FASB and the PCAOB’s new priorities and leadership. Scott moderated a panel entitled “Recent Developments in Digital Assets and Tokenization,” which explored the impact of tokenization, ETFs and digital asset treasury companies, new crypto legislation and what lies ahead. Justin moderated a panel entitled “Private Securities Litigation – 2025 Developments and Trends,” which analyzed trends in securities class action filings, case law updates and new and developing issues.
Publications
February 13, 2026
Cravath Venture Capital & Growth Equity Insights: 2025 Recap and 2026 Outlook
On February 13, 2026, Cravath published the latest edition of its Venture Capital & Growth Equity Insights newsletter, which provides insight into global venture capital and related activity during 2025 and an outlook for the coming year. Key takeaways from this edition include:
Activities
February 13, 2026
Scott Bennett, Elad Roisman, Nick Dorsey and Sasha Rosenthal‑Larrea Featured in Lawdragon’s “Lawyer Limelight” Series
On February 12, 2026, Cravath partners D. Scott Bennett, Elad Roisman, Nicholas A. Dorsey and Sasha Rosenthal‑Larrea were profiled in Lawdragon’s “Lawyer Limelight” series in connection with the Firm’s work for “companies at the forefront of innovation in digital assets, AI, fintech, biotech, media and emerging technologies.”
Activities
February 13, 2026
Scott Bennett Moderates “Legal as a Strategic Partner: Best Practices for Contracts and Product‑Related Matters” Roundtable at The L Suite’s GC Dinner
On February 12, 2026, Cravath partner D. Scott Bennett participated in The L Suite’s General Counsel Roundtable Dinner in New York. Scott moderated a discussion between chief legal officers and general counsels at high‑growth tech companies and venture funds on the topic “Legal as a Strategic Partner: Best Practices for Contracts and Product‑Related Matters.”
Publications
December 29, 2025
Section 16(a) Share Ownership and Transaction Reporting Obligations to Apply to Directors and Officers of Foreign Private Issuers from March 18, 2026
On December 23, 2025, Cravath prepared a memo for its clients entitled “Section 16(a) Share Ownership and Transaction Reporting Obligations to Apply to Directors and Officers of Foreign Private Issuers from March 18, 2026.” The memo examines the Holding Foreign Insiders Accountable Act and how directors and officers of foreign private issuers will be required to comply with the share ownership and transaction reporting obligations of paragraph (a) of Section 16 of the Securities Exchange Act of 1934 within 90 days of the enactment of the 2026 U.S. National Defense Authorization Act.
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