Georgia Tech Cyber Case: From Allegations to Settlement—and What It Signals for DoD Contractors

The Justice Department’s announcement that Georgia Tech Research Corporation will pay $875,000 to resolve civil cyber-fraud allegations closes the loop on a narrative we previously covered: the federal government’s willingness to use the False Claims Act to enforce contractual cybersecurity obligations. Our earlier post summarized DOJ’s intervention against Georgia Tech and its contracting arm over alleged failures to implement required controls on systems handling covered defense information and to accurately report cybersecurity posture. The settlement now provides a concrete endpoint—and a practical roadmap for contractors navigating NIST SP 800-171 performance, interim self-assessments, and the maturation path toward CMMC. (Fed Contract Pros™)

According to DOJ, the case focused on research performed at Georgia Tech’s Astrolavos Lab under U.S. Air Force and DARPA contracts. The United States alleged that, until December 2021, antivirus or anti-malware tools were not installed, updated, or run across workstations, servers, and networks that processed sensitive DoD information; that the lab lacked a system security plan at least until February 2020; and that a December 2020 campus-wide “summary level” assessment score submitted to DoD was allegedly false because it was premised on a fictitious or virtual environment and not on actual covered systems. DOJ emphasized that the obligation to implement NIST SP 800-171 controls has applied to DoD awards since 2017 and reiterated that CMMC—recently finalized—will further formalize assessment expectations. The settlement provides relators, two former members of Georgia Tech’s cybersecurity team, a $201,250 share; DOJ also underscored that the claims were allegations only and that there has been no determination of liability. (Department of Justice)

For defense contractors, the message is unambiguous. First, cybersecurity is not merely an internal IT hygiene program; it is a performance requirement that goes to the heart of contractual compliance. DOJ’s theory connects day-to-day control operation—antivirus deployment, documented system security plans, accurate self-assessments—to material eligibility for award and continued performance. Second, the government is comfortable fusing technical and legal levers: investigative resources from DCIS and AFOSI, programmatic oversight from DoD CIO, and FCA remedies from DOJ. This multidisciplinary posture means that gaps once dismissed as “IT clean-up items” can escalate to enterprise-level legal risk. Third, the qui tam dimension continues to matter. Organizations should assume that employees closest to the controls—and to the artifacts of compliance, like assessment submissions—are best positioned to spot inconsistencies. That reality argues for robust internal reporting channels, independent compliance assurance, and swift corrective action when discrepancies surface.

The practical lesson aligns with what we previously advised: treat NIST SP 800-171 as a living control set with documented ownership, evidence, and continuous monitoring; ensure that assessment scores and submissions correspond to the systems actually processing, storing, or transmitting covered defense information; and build a defensible thread from contract clause to control to artifact. If CMMC increases scrutiny, contractors who can already show control operation, testing, and truthful attestations will be better positioned—legally and competitively—when audits and validations arrive. The Georgia Tech resolution is not a one-off; it is a preview of the compliance standard the government expects across the Defense Industrial Base. (Fed Contract Pros™)

Disclaimer: This article is for general informational purposes only and does not constitute legal advice. The DOJ press release notes that the claims resolved by the settlement are allegations only and that there has been no determination of liability. Consult qualified counsel regarding specific facts and contracts. (Department of Justice)