The start of a new year presents an opportune time to reflect on the past. We have been tracking and reporting on the U.S. Department of Justice (“DOJ”)’s Civil Cyber-Fraud Initiative (“CCF Initiative”), which former U.S. Deputy Attorney General Lisa O. Monaco announced in October 2021. The CCF Initiative employs the powerful False Claims Act (“FCA”) in an effort to “hold accountable entities or individuals that put U.S. information or systems at risk by (1) knowingly providing deficient cybersecurity products or services, (2) knowingly misrepresenting their cybersecurity practices or protocols or (3) knowingly violating obligations to monitor and report cybersecurity incidents and breaches.”
We previously offered insight into the first two FCA enforcement actions brought under this initiative, then a third, and a fourth. 2024 brought even more.
Towards the end of 2024, on October 22, 2024, DOJ announced an FCA settlement with a major public university relating to its alleged failure to comply with cybersecurity requirements for more than a dozen Department of Defense (“DOD”) and National Aeronautics and Space Administration (“NASA”) contracts and subcontracts. The university agreed to pay $1.25M to resolve allegations that it violated the FCA by failing to comply with cybersecurity requirements in fifteen contracts or subcontracts involving the DOD or NASA. The settlement resolves allegations brought by a chief information officer for the university’s Applied Research...
Member of the group DJ DOC, Lee Ha-neul has announced a counter-suit against singer Jubi Train and the representative of his agency BASS Camp Studio. On the 21st, BASS Camp Studio issued an offici...