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DoD’s Stocking Stuffer: Defense Department Announces Proposed CMMC Pilot Programs

Client Alert | 1 min read | 12.21.20

This week, the DoD announced the first group of pilot programs under the Cybersecurity Maturity Model Certification. Although still under review, these programs will likely be among a small group to issue solicitations in FY2021 that will require a CMMC certificate to be eligible for award. The DoD expects to identify eight other programs in the coming weeks, bringing the total number of FY2021 solicitations subject to CMMC up to 15. Each program is expected to require a Level 3 certificate for primes, and either a Level 3 or Level 1 certificate for every subcontractor, with limited exceptions.

U.S. Navy

  • Integrated Common Processor
  • F/A-18E/F/ Full Mod of the SBAR and Shut Off Valve
  • DDG-51 Lead Yard Services / Follow Yard Service

U.S. Air Force

  • Mobility Air Force Tactical Data Links
  • Consolidated Broadband Global Area Network Follow-On
  • Azure Cloud Solution

Missile Defense Agency

  • Technical Advisory and Assistance Contract

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Client Alert | 5 min read | 08.21.26

FTC Proposes Enforcement Policy Statement on Personalized Pricing: What Businesses Need to Know

On August 19, 2026, the Federal Trade Commission (FTC) announced a proposed Enforcement Policy Statement on personalized pricing — the practice of companies using consumers’ personal data to set individualized prices, discounts, coupons, or other incentives. The proposed statement, which is open for public comment for 30 days following publication in the Federal Register, marks a major step up in the FTC’s focus on data-driven pricing strategies and puts businesses across industries on notice that undisclosed or inadequately disclosed personalized pricing will not be tolerated. Importantly, while the proposed statement is not a binding legal requirement and does not create new legal obligations, it serves as an enforcement warning that the FTC is prepared to use its existing enforcement authority under Section 5 of the FTC Act (Section 5) and is also a potential harbinger of rulemaking. Businesses that engage in — or are considering — personalized pricing should carefully assess their disclosure practices and data collection procedures against the standards articulated in this statement....

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