Applying principles of contract interpretation, the Federal Circuit held the CFC had erred. The release unambiguously referred to "any and all liability," and there was no ambiguity about which types of claims were released. At best, there could be ambiguity as to which claims were "attributable to" a particular modification, and on remand the CFC was to determine which of the contractor's claims were attributable to modifications that did not contain the release language. In addition, the contractor's release for the additional floor modification was supported by adequate consideration, but the CFC needed to determine whether the government provided adequate consideration for the other modifications containing the release language.
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