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.
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On 3 September 2026, the European Commission adopted new Guidelines on the application of Article 102 TFEU to abusive exclusionary conduct by dominant undertakings. The Guidelines follow a public consultation on a draft published in August 2024 and reflect substantial stakeholder feedback. They replace the Commission's 2008 Guidance on enforcement priorities (which ceases to apply 30 days after publication of the new guidelines in the Official Journal) and represent the most significant reset of the Commission's Article 102 enforcement framework in nearly two decades. The Commission's stated aim is to set out principles and operational guidance, enhance legal certainty, and help companies self-assess their exclusionary-abuse risk.
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IRS Takes Aim: Proposed Rule Threatens Tax-Exempt Status of Private Schools


