An Opening Salvo for Cybersecurity FCA Cases
Client Alert | 1 min read | 08.06.19
On July 31, 2019, Cisco Systems agreed to pay $8.6 million to settle allegations in United States ex rel Glenn, et al v. Cisco Systems, Inc. that the company violated the False Claims Act (FCA) by selling video surveillance systems to state and federal agencies that contained software flaws enabling those agencies to be hacked. An employee of one of Cisco’s resellers filed the suit in 2011 after discovering the alleged security weakness that could permit a cyber intruder to obtain administrative access to the software that managed video feeds.
The cybersecurity specialist alleged in his complaint that the company violated the FCA by (1) failing to inform government agencies that the software did not comply with the standards imposed by the Federal Information Security Management Act (FISMA) and (2) by providing a product that was worthless due to the security flaws in the software. Although this settlement marks the first time that a cybersecurity related qui tam has ended in a recovery through a settlement or judgment, it appears to be a sign of the times. As more such cases—alleging noncompliance with the DFARS Safeguarding Rule or FedRAMP requirements— are investigated and proceed through the courts, Glenn could be the first of many such recoveries.
Contacts
Insights
Client Alert | 7 min read | 12.17.25
After hosting a series of workshops and issuing multiple rounds of materials, including enforcement notices, checklists, templates, and other guidance, the California Air Resources Board (CARB) has proposed regulations to implement the Climate Corporate Data Accountability Act (SB 253) and the Climate-Related Financial Risk Act (SB 261) (both as amended by SB 219), which require large U.S.-based businesses operating in California to disclose greenhouse gas (GHG) emissions and climate-related risks. CARB also published a Notice of Public Hearing and an Initial Statement of Reasons along with the proposed regulations. While CARB’s final rules were statutorily required to be promulgated by July 1, 2025, these are still just proposals. CARB’s proposed rules largely track earlier guidance regarding how CARB intends to define compliance obligations, exemptions, and key deadlines, and establish fee programs to fund regulatory operations.
Client Alert | 1 min read | 12.17.25
Client Alert | 7 min read | 12.17.25
Executive Order Tries to Thwart “Onerous” AI State Regulation, Calls for National Framework
Client Alert | 4 min read | 12.17.25
The new EU Bioeconomy Strategy: a regulatory framework in transition


