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
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  recognizing that because subcontractor was not a contractor as defined in the cda there was no cda jurisdiction to consider its direct appeal 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 holding that plaintiffs letters do not constitute a cda claim in part because there was a complete lack of certification holding that sending only four letters to student as collection effort did not constitute lack of diligence