On July 8, 2022, the U.S. Department of Justice announced a $9 million
settlement with federal government contractor Aerojet Rocketdyne, Inc. for
alleged violations of the False Claims Act in a case pending in the Eastern
District of California. The settlement results from alleged false
statements by Aerojet related to compliance with Department of Defense
cybersecurity requirements described in DoD Federal Acquisition Regulation
Supplement clause 252.204-7012 and National Aeronautics and Space
Administration Federal Acquisition Regulation Supplement clause
1852.204-76. The settlement further underscores DOJ’s commitment to FCA
enforcement actions involving cybersecurity considerations related to its
Civil Cyber-Fraud Initiative announced in October 2021. The settlement
serves as a clear reminder to contractors that DOJ and the plaintiffs’ qui tam bar are taking the Cyber-Fraud Initiative seriously.

Read on to learn why a close understanding of and adherence to federal
agency contractual cybersecurity requirements are important mandates for
the government contracting community broadly and the defense industrial
base in particular.

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Photo of Edwin O. Childs Edwin O. Childs

Ned Childs is a government contract and investigations and enforcement attorney who represents companies across a wide range of sectors, including the defense, services, technology, and aerospace industries. His practice, spanning more than a decade in Washington, encompasses a broad array of legal…

Ned Childs is a government contract and investigations and enforcement attorney who represents companies across a wide range of sectors, including the defense, services, technology, and aerospace industries. His practice, spanning more than a decade in Washington, encompasses a broad array of legal services, including government contract investigations, disclosures, and regulatory enforcement actions; bid protests and government contract disputes; government contract counseling; export licensing and enforcement; prime contractor-subcontractor disputes; corporate ownership and acquisition issues; and election law investigations and enforcement matters.

Photo of Todd R. Steggerda Todd R. Steggerda

Todd Steggerda is Chair of the firm’s Government Investigations and White Collar Litigation department, which was recently recognized by Law360 as a Practice Group of the Year. In a dynamic practice spanning nearly 20 years in Washington, Todd has resolved a diverse range…

Todd Steggerda is Chair of the firm’s Government Investigations and White Collar Litigation department, which was recently recognized by Law360 as a Practice Group of the Year. In a dynamic practice spanning nearly 20 years in Washington, Todd has resolved a diverse range of high-stakes government investigations and regulatory enforcement matters for companies operating in the defense, national security, technology, healthcare and other sectors, including dozens of matters investigated by the civil and criminal divisions of the Department of Justice and the Department of Defense. Todd previously served as Chief Counsel to a Presidential Campaign.

Photo of Abram J. Pafford Abram J. Pafford

Abe is an experienced litigator who represents government contractors across the full spectrum of government contract matters, including litigation, appeals, administrative proceedings and investigations. As a member of the firm’s nationally recognized Government Investigations and White Collar department, Abe prosecutes claims arising under…

Abe is an experienced litigator who represents government contractors across the full spectrum of government contract matters, including litigation, appeals, administrative proceedings and investigations. As a member of the firm’s nationally recognized Government Investigations and White Collar department, Abe prosecutes claims arising under the Contract Disputes Act, defends against False Claims Act lawsuits initiated by the Department of Justice, and represents protestors and intervenors in pre-award and post-award bid protests before the United States Court of Federal Claims and the GAO.

Photo of Andrew Konia Andrew Konia

Andrew’s practice is singularly focused on protecting clients’ businesses and data, anticipating disputes, and strengthening their competitive position in the marketplace.

Photo of Jason M. Vespoli Jason M. Vespoli

Jason focuses his practice on federal and state procurement, government technology, bid protests and government contract disputes, and regulatory compliance. He utilizes experience in state government, government technology, and complex procurement to solve problems in innovative and efficient ways.

Photo of Sydney L. Snower Sydney L. Snower

Sydney is a member of the firm’s Government Investigations and White Collar Litigation practice. Her practice focuses on criminal and civil investigations, including in the financial services, government contracting, aviation, and accounting industries.