DoD Issues Long-Awaited Interim Rule on Cyber Requirements and Cloud Services
Client Alert | 1 min read | 09.03.15
As discussed in our recent blog post, on August 26, DoD published an Interim Rule that would expand the already onerous requirements of the DFARS Safeguarding Clause by broadening its application to "covered defense information" and by requiring subcontractors to report cyber incidents directly to DoD. As discussed in a separate blog post, the Interim Rule also seeks to ensure uniformity in the DoD's IT acquisition and use of cloud computing services by adding T&C's, including that, unless otherwise authorized, cloud service providers must maintain all government data within the U.S., outlying areas, or DoD premises.
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The U.S. Government Accountability Office’s (GAO) recent decision in Viderity Inc.—Costs, B-424422.5, Sept. 1, 2026, offers useful insight into what constitutes a legally sufficient conflict of interest investigation. The decision arose in an unusual procedural posture: Viderity initially protested, alleging that an agency evaluator had a personal conflict of interest. After the agency took corrective action, Viderity filed a cost entitlement claim requesting that GAO direct the agency to reimburse Viderity’s protest costs. In evaluating that claim, GAO assessed whether Viderity’s underlying protest ground was “clearly meritorious.”
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