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CMMC Phase II Follow-Up: New FAR Part 40, CUI and Contractor Action Items

By Seamus Curley and Taylor Vogel
October 22, 2026
  • Data and Software Rights, Patent Rights and Cybersecurity
  • General
  • Government Contracts
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Our July 15, 2026 alert explained the Department of War’s (“DoW”) suspension of Cybersecurity Maturity Model Certification (“CMMC”) Phase II implementation and the immediate implications for defense contractors. This follow-up alert focuses on recent developments to the CMMC Program and related cybersecurity compliance obligations.

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CMMC, Cybersecurity, government contracts
Seamus Curley

About Seamus Curley

Seamus Curley is a partner in the Firm’s Government Contracts practice where he focuses on government contracts counseling, litigation and internal and government investigations. Seamus has litigated in state and federal courts throughout the country, including under multiple pro hac vice admissions, and before administrative forums, including the US Court of Federal Claims (COFC), the US Government Accountability Office (GAO), the US Civilian Board of Contract Appeals (CBCA), the Armed Services Board of Contract Appeals (ASBCA) and the US Small Business Administration Office of Hearings and Appeals (SBA OHA) on bid protests, size protests/appeals, Contract Disputes Act (CDA) claims, and commercial litigation matters.

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Taylor Vogel

About Taylor Vogel

Taylor is an associate in Dentons’ Government Contracts practice, focusing on a range of government contracts matters, including developments in cost accounting standards, the Federal Acquisition Regulation and domestic and international government contracting.

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