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Department of Defense Finalizes Long-Awaited Cybersecurity Rule

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On September 10, 2025, the U.S. Department of Defense (DoD) published its long-awaited final rule amending the Defense Federal...

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On September 10, 2025, the U.S. Department of Defense (DoD) published its long-awaited final rule amending the Defense Federal Acquisition Regulation Supplement (DFARS) to incorporate contractual requirements related to the Cybersecurity Maturity Model Certification (CMMC) program. The final rule begins a phased-in approach under which, within the next three years, nearly all DoD solicitations and contracts will require contractor conformance to one of three levels of cybersecurity requirements. Read the <a href="https://govcon.mofo.com/topics/department-of-defense-finalizes-long-awaited-cybersecurity-rule" target="_blank">full blog post</a>.

Department of Defense Finalizes Long-Awaited Cybersecurity Rule

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Tina is co-chair of Morrison Foerster’s Government Contracts & Public Procurement practice. She represents a wide variety of government contractors including information technology, defense, biotechnology, and pharmaceutical companies, as well as research organizations and universities, with a focus on general contract counseling and compliance, intellectual property and cybersecurity matters, federal grant funding, and state and local government contracting matters.Tina routinely advises clients on:<ul><li>Contract negotiations and prime-subcontractor relationships</li><li>Sources of supply and country of origin requirements</li><li>Organizational conflicts of interest and other ethics considerations</li><li>Safeguarding of intellectual property and other proprietary interests</li><li>Licensing and data rights issues</li><li>Handling of classified materials and controlled unclassified information</li><li>Freedom of Information and Public Records Act requests</li></ul>She also conducts due diligence and other activities related to the acquisition of government contracting concerns, and drafts and negotiates teaming agreements, subcontracts, licensing agreements, and cooperative research and development agreements, Small Business Innovative Research (“SBIR”) and Small Business Technology Transfer Program (“STTR”) agreements, and other transaction authority (“OTA”) agreements.Tina’s litigation experience includes government contracts claims litigation in federal courts and before boards of contract appeals, bid protests before the Government Accountability Office and the Court of Federal Claims, and complex disputes in federal courts, including civil fraud and False Claims Act litigation, and reverse Freedom of Information Act litigation.Prior to joining Morrison Foerster, Tina worked at another large national firm and as a trial attorney in the U.S. Department of the Navy, Office of the General Counsel, Navy Litigation Office.<h4>Recent Representative Experience</h4><ul><li>Negotiated the largest CHIPS Act federal funding agreement between a multinational semiconductor corporation and the U.S. Department of Commerce. </li><li>Negotiated a prime contract and major subcontracts related to the Department of Energy’s next generation supercomputer program, including extensive IP rights and associated patent rights waivers. </li><li>Negotiated a series of other transaction authority agreements with DARPA and associated subcontracts with more than a dozen research universities on behalf of a firm biotech client, including complex IP rights allocations and material transfer agreements. </li><li>Assisting clients with the FedRAMP authorization process and the development of license agreements for software products sold to federal, state, and local government agencies. </li><li>Providing cyber incident response counseling to some of the largest companies and organizations impacted by security incidents, many involving nation state threat actors. </li><li>Advising clients on Bayh-Dole reporting of inventions and IP strategies for contracts and grants. </li><li>Conducting due diligence for major government contract mergers and acquisitions, including, for example, Salesforce’s $8 billion acquisition of Informatica and Palo Alto Networks’ $25 billion acquisition of CyberArk. </li><li>Advising clients on litigation strategy for False Claims Act matters, including those being handled by the U.S. Department of Justice (DOJ) cyber fraud initiative.</li></ul>

Tina D. Reynolds

Partner

Cody Fisher is an associate in Morrison Foerster’s Government Contracts and Public Procurement practice.Cody is an associate in Morrison Foerster’s Government Contracts and Public Procurement practice where she assists with litigation, investigations, M&A due diligence, and other matters related to federal contracts and grants. She has a particular interest in contract claims and disputes, government contracts compliance, teaming agreements, and False Claims Act matters.Cody graduated cum laude from Georgetown University Law Center, where she was a member of the Appellate Litigation Clinic, briefing a case before the U.S. Court of Appeals for the Fourth Circuit. She was recognized with the Georgetown Law Pro Bono Pledge honor and served on the student executive board of the Journal of National Security Law and Policy.During law school, she worked as a law clerk for Morrison Foerster’s Government Contracts practice and participated in the firm’s summer associate program. She also interned for the Honorable Carolyn Lerner at the U.S. Court of Federal Claims. Before attending law school, Cody served as Director of Government Affairs for the National Head Start Association. Prior to that, she was a kindergarten teacher in Taiwan.Cody earned her B.A. in Classics, History, and Politics from Colorado College, where she played NCAA Division I soccer, was named to the C-USA Commissioner’s Honor Roll, and was inducted into the Phi Sigma Iota honor society.