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No More "Wait & See" for CMMC: DoD Releases Final Cybersecurity Maturity Model Certification

Client Alert | 1 min read | 02.03.20

The Department of Defense (DoD) has released Version 1.0 of the Cybersecurity Maturity Model Certification (CMMC), Appendices A-F, and an Overview Briefing. While Version 1.0 largely mirrors the draft Version 0.7, the final version includes notable revisions, such as:

  • Process and Practice Descriptions in Appendix B, which include discussions and clarifications for every “practice” within each CMMC Level, including the long-awaited examples for Levels 4 and 5; and
  • Source Mapping in Appendix E, which maps each “practice” across all five Levels –171 in total – to other pre-existing cybersecurity frameworks.

Much, however, remains to be done. In anticipation of the DoD adopting “go/no-go” CMMC certification requirements later this year, a privately-run Accreditation Body is expected to begin training third-party assessors (3PAOs) this spring in conducting those certifications for contractors. Simultaneously, the DoD is expected to issue a proposed rule incorporating the CMMC into DFARS 252.204-7012, to be finalized this fall. 


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Client Alert | 3 min read | 07.18.25

Eighth Circuit Cancels Click-to-Cancel

On July 8, 2025, the Eighth Circuit vacated the Federal Trade Commission’s (“FTC”) Negative Option Rule, also known as the Click-to-Cancel Rule, on procedural grounds. The Click-to-Cancel Rule, which provided a streamlined path for consumers to cancel subscription services in a few clicks of a mouse, was scheduled to take effect on July 14, 2025, but the Court found that the FTC had failed to follow mandatory procedural requirements....