With no explanation, chose the best option from "A", "B", "C" or "D". cost basis. 48 C.F.R. § 49.602-1. (1999) (prescribing the use of SF 1436); 48 C.F.R. § 53.249(a)(3) (same); see also 48 C.F.R. § 49.104(h) (requiring contractor to submit a settlement proposal following convenience termination). 10 . Id. at 1545. Scan-Tech additionally cites J & E Salvage to support its argument. J & E Salvage offers statements questioning the requirement of certification as a result of Ellett Construction, but these statements are merely dicta, nonessential to the court’s holdings. Any doubt created in the aftermath of Ellett Construction and J & E Salvage was not evident in the court’s recent ruling in which it confirmed that ”[t]he absence of certification on a claim in excess of $100,000.00 is fatal to jurisdiction.” Hamilton Sec. Advisory Servs., 43 Fed.Cl. at 576 (<HOLDING>). 11 . For this court’s analysis of J & E

A: recognizing that because subcontractor was not a contractor as defined in the cda there was no cda jurisdiction to consider its direct appeal
B: holding that plaintiffs letters do not constitute a cda claim in part because there was a complete lack of certification
C: holding that attorney fees awarded under the common fund doctrine do not constitute part of a plaintiffs claim against the defendant and cannot be considered for amountincontroversy purposes
D: holding that the tucker act gives the united states court of federal claims jurisdiction over cda claims only when a decision of the contracting officer has been issued under section 6 of the cda
B.