Michael G. Gruden

Cybersecurity Assessments & Compliance Architecture

• Strategic Cybersecurity Counsel & Architecture: Served as cybersecurity counsel to a premier global financial services corporation, a national healthcare provider, and Fortune 100 leaders in the aerospace, automotive, and critical communications sectors; provided technical and regulatory guidance on network scoping, boundary definitions, security control implementations, and the cross-interpretation of federal and commercial cyber requirements.
• Privileged CMMC Mock & Certification Assessments: Conducted extensive, privileged CMMC mock and certification assessments to ensure compliance with defense cybersecurity requirements for market-leading clients, including global hyperscalers, major aerospace and defense contractors, top-tier commercial infrastructure firms, and Fortune 500 industrial technology manufacturers.
• CUI Decontrol & Data Strategy: Represented a multinational pharmaceutical manufacturer to successfully decontrol integral operational data originally designated as federally regulated Controlled Unclassified Information (CUI)—effectively expanding commercial production capabilities and reducing systemic cybersecurity compliance risks.
• Software Security Assessments: Executed comprehensive, privileged software security assessments for a premier federal information technology integrator and a top-tier commercial infrastructure and civil engineering firm, ensuring system architecture integrity and regulatory alignment with federal third-party risk mandates.

Incident Response & Crisis Management

• International Ransomware Crisis Management: Served as lead crisis counsel and directed the privileged forensic investigation for a global enterprise IT and digital transformation provider following a large-scale ransomware event; orchestrated comprehensive crisis communications and multi-jurisdictional data breach notifications across prominent global intergovernmental bodies, United Nations agencies, and international treaty and defense organizations.
• Multinational Breach Response & Disclosure: Strategized and orchestrated the global incident response and forensic investigation for a critical infrastructure operator following a sophisticated ransomware attack, directing complex regulatory disclosure determinations under compressed statutory timelines.
• FedRAMP & AI Incident Notification: Advised global cloud infrastructure hyperscalers and leading artificial intelligence (AI) companies on complex FedRAMP regulatory notice requirements, multi-agency reporting obligations, and strategic disclosure protocols following high-stakes cloud security incidents.
• Venture Capital Data Breach Strategy: Retained by a premier venture capital firm and startup incubator following a cybersecurity incident to isolate and determine impacted investor data, executing a strategic compliance review to manage all necessary commercial and financial regulatory notice requirements.
• Executive Tabletop Exercises: Designed and executed privileged, high-pressure simulated cyber incident exercises for executive leadership teams and corporate boards of major enterprise clients to stress-test corporate governance, response protocols, and strategic decision-making.

Cyber False Claims Act Investigations & Defense

• Privileged Government Disclosure Investigations: Conducted high-stakes privileged investigations for enterprise hyperscalers, a prominent commercial aviation carrier, a national health plan payer, a leading medical device manufacturer, and a multinational energy infrastructure leader to evaluate compliance with federal standards—including NIST SP 800-171, FedRAMP, and CMMC—and direct complex voluntary or mandatory government disclosure determinations.
• FCA Cyber Whistleblower Defense: Served as lead cyber counsel for a Tier 1 Aerospace & Defense contractor in a high-stakes civil False Claims Act (FCA) qui tam investigation alleging non-compliance with federal cybersecurity frameworks, resulting in a favorable resolution with federal regulators.
• Multi-Year Managed Care FCA Defense: Served as a cybersecurity subject matter expert in the multi-year defense of a major national managed care enterprise facing multiple high-stakes civil False Claims Act (FCA) qui tam investigations; extensively relied upon by senior defense counsel and executive leadership to drive the technical defense strategy, evaluate complex regulatory data security requirements, and anchor technical positioning throughout federal settlement negotiations.

Government Experience

US Department of Defense

Branch Chief for Information Technology and Physical Security Acquisitions at Washington Headquarters Services (WHS), a 4th Estate Department of Defense (DoD) field activity responsible for the contracting needs of the Office of the Secretary of Defense (OSD) and the Pentagon Reservation. As an unlimited warrant Contracting Officer, Michael awarded, oversaw the award of or acted as the Source Selection Authority (SSA) of:

• $500 million solicitation for information technology services spanning the entire Pentagon Reservation, where Michael worked with the Chief Information Officer and other Senior Executive Service members to develop the acquisition strategy and request for proposal (RFP).
• Courtroom technology contracts at Guantanamo Bay, Cuba for 9/11 detainee military tribunals.
• 24/7 global information technology support for the Office of the Secretary of Defense and its advance staff.
• Travel agreements for the Secretary of Defense’s outside the continental United States (OCONUS) and all CONUS travel.
• Modernization of IT infrastructure for DoD’s primary alternate site, continuity of operations (COOP) facility.
• Satellite tower construction and information technology development in the Asian Pacific to landmark drug, human, and weapon trafficking in concert with U.S. partnering nations.
• Wargaming, modeling, and simulation contracts in support of the war planning directorate of OSD.
• Cooperative agreement for glass manufacturing facility in Afghanistan.
• Security installation and repair services for electronic security systems and infrastructure throughout the Pentagon Reservation.
• Meteorological and laboratory services for Chemical, Biological, Radiological, Nuclear (CBRNE) defense.
• Michael was detailed for six months to the Office of the General Counsel, where he assisted attorneys in the defense of protests filed before the Government Accountability Office (GAO) and the U.S. Court of Federal Claims (COFC).

US Department of Homeland Security

Acquisition Professional at DHS Headquarters supporting Science & Technology (S&T) Directorate and Homeland Security Advanced Research Projects Agency (HSARPA), among others; Contracting Officer at Immigration and Customs Enforcement (ICE). Collectively, In those roles, Michael worked to:

• Led renovations for multiple DHS alternate site continuity of operations facilities, managing a suite of renovation construction contracts encompassing data centers, supervisory control and data acquisition (SCADA) systems, power grids, and water treatment facilities.
• Administered a Broad Agency Announcement (BAA) solicitation encompassing all program missions within S&T. Engaged with industry regarding the BAA and liaised among industry, members of Congress, the Executive Director of S&T, and program offices.
• Awarded cybersecurity and CBRNE contracts for S&T and HSARPA.
• Partnered with the Office of Security to award essential information technology software and hardware contracts.

• "New Cybersecurity Maturity Model Certification Program: Compliance Obligations & Implications for DoD Contractors," BARBRI, December 10, 2025
• "Key Takeaways from DOJ's Civil Cyber-Fraud Initiative," ABA Cyber Meeting, December 5, 2025
• "Cyber Year in Review," The Coalition for Government Procurement, December 3, 2025
• "CMMC Level 2: How to Start Preparing," 2025 PreVeil Virtual CMMC Summit, October 29, 2025
• "Legal Risks and False Claims Act Exposure from CMMC Self-Attestations and C3PAO Certifications," CS5 East 2025, October 17, 2025
• "Legal Insights: Regulatory Landscape," CyberSheath 2025 Customer Advisory Board (CAB) Event, September 18, 2025
• "Cyber Update," The Coalition for Government Procurement, August 28, 2025
• "CMMC July 2025 Town Hall," The Cyber AB, July 29, 2025
• "CMMC Full Speed Ahead," Preveil, April 2, 2025
• "Cybersecurity Landscape Update," Coalition for Government Procurement, March 27, 2025
• Contracting Officer & General Counsel Perspectives on CMMC Supply Chain Security, November 21, 2024
• "Cybersecurity and Government Contracts," 2nd Annual Midwest Government Contracts Seminar, Chicago, IL., October 29, 2024
• Cybersecurity Symposium: The Cyberside Chat, Seminar, September 12, 2024
• "Arresting Disaster: Driving Individual and Sector Wide Incident Response in an Age of AI Threats," NRECA Co-op Cyber Tech Track: Current and Future State of Ransomware, Crystal City, VA, June 12, 2024
• A Former Contracting Officer's Peek into Your Supply Chain, April 3, 2024
• "Who is Going to Pay for This? - Cyber Cost Allowability and Pricing Strategies in a Post-CMMC World," CIC 2024 Conference, March 15, 2024
• "About the False Claims Act…from a Service Provider's Perspective," CMMC Implementation Conference (CIC), San Diego, CA, March 13, 2024
• "Tenth Annual Legal Careers in Cybersecurity, Privacy, and Information Law," American Bar Association Seminar, Washington, D.C., November 30, 2023
• “The Evolving Cybersecurity Framework: A Briefing,” The Coalition for Government Procurement's 2022 Fall Conference, Falls Church, VA., November 15, 2023
• "Legal Considerations," Washington Technology's CMMC 2.0 Ecosystem Summit, McLean, VA, November 8, 2023
• "The Evolution of CMMC," National Contract Management Association, DC Chapter, February 15, 2023
• "FY2023 NDAA: Need-to-Know Provisions for Government Contractors," National Contract Management Association, January 18, 2023
• "Cyber Expectations," The Coalition for Government Procurement's 2022 Fall Conference: Expectations for Gov Fiscal Year 2023, Falls Church, VA., November 16, 2022
• "Legal Spotlight," Washington Technology CMMC 2.0 Ecosystem Summit, McLean, VA., November 9, 2022
• CMMC 2.0 and the Rise of False Claims Act Cyber Liability – Coalition for Government Procurement, October 27, 2022
• "A New Flightpath for Cybersecurity: How to Strengthen Your Infrastructure and Understand Your Cyber Readiness," Association of Corporate Counsel Webinar, February 1, 2022
• "FY2022 NDAA" National Contract Management Association, January 28, 2022
• “Dissecting CMMC 2.0” National Contract Management Association, January 27, 2022
• "FY22 NDAA Need to Know Provisions," National Contract Management Association Space Coast Chapter, January 12, 2022
• "Privacy & Cybersecurity Updates," North Alabama Federal Bar Association Acquisition Law Symposium, December 15, 2021
• "SolarWinds SUNBURST & Supply Chain Security," American Bar Association Public Contract Law Section, April 1, 2021
• "Cybersecurity & Privacy Updates," North Alabama Federal Bar Association Acquisition Law Symposium, December 4, 2020
• "Cutting Edge Cybersecurity Developments," North Alabama Federal Bar Association Acquisition and Employment Symposia, November 12, 2019

Notable Publications

• Why Your Institution May Face Enhanced Cybersecurity Requirements, University Business, October 16, 2024
• The Impact of the Cybersecurity Maturity Model Certification on the Defense Industrial Base, Contract Magazine, May 1, 2024
• What Sections 9 And 10 Of the Executive Order on AI Mean for Government Contractors, Federal News Network, January 15, 2024
• SolarWinds Whips Up a Software Cybersecurity Storm, Contract Management Magazine, January 2024
• Spy Games: Biden Administration Issues Executive Order Restricting Federal Use of Commercial Spyware, Government Contracting Law Report, June 15, 2023
• Planning For the Uncertain: What to Watch and How to Prepare For CMMC, Federal News Network, May 23, 2023
• The Road To CMMC: Where We Started and Where We Are Headed, Westlaw Today, Reuters, March 30, 2023
• Cybersecurity Provisions Proliferate in the National Defense Authorization Act, Government Contracting Law Report, March 15, 2022
• A New Flightpath for Cybersecurity, ACC Docket, September 8, 2021
• Navigating The SolarWinds Supply Chain Attack, The Procurement Lawyer, March 25, 2021
• Defending Cybersecurity False Claims Act Allegations, Bloomberg Law, September 18, 2019
• Finally, Cyber Help for Small Businesses Is on Its Way, Law360, October 1, 2018

• Branch Chief / Supervisory Contracting Officer, Washington Headquarters Services, Office of the Secretary of Defense, 2012–2017
• Contracting Officer, US Immigration and Customs Enforcement, 2011–2012
• Senior Contract Specialist, DHS Headquarters, 2005–2011

• Certified Information Privacy Professional/Government (CIPP/G)
• American Bar Association Science & Technology Section, Homeland Security Committee (Chair)
• Cybersecurity Maturity Model Certification Accreditation Body Appeals Board
• Cyber AB Registered Practitioner