Civil Law

“DOJ’s $2 Million Honeywell Settlement Under the Civil Cyber-Fraud Initiative: What Compliance Failures Mean for Defense Contractors

Key Takeaways

  • DOJ used the FCA to settle with Honeywell Aerospace Inc. for $ 2,042,518 over allegations that a Honeywell business unit submitted claims for payment under a DoW contract while failing to comply with NIST SP 800-171 cybersecurity requirements incorporated through DFARS 252.204-7012, reinforcing that cybersecurity compliance failures can create significant FCA exposure for defense contractors.
  • The settlement arose from a 2022 qui tam whistleblower action filed by a former Honeywell employee, and DOJ reported a record
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Civil Law

Partial compliance is noncompliance: Lessons from California’s $2.75 million settlement with Disney

On February 11, 2026, California Attorney General Rob Bonta announced a $ 2.75 million settlement with The Walt Disney Company (“Disney”), the largest civil penalty to date under the California Consumer Privacy Act as amended by the California Privacy Rights Act (collectively, “CCPA”), resolving claims that Disney’s opt-out mechanisms did not fully satisfy CCPA requirements. This settlement stems from California’s 2024 investigative sweep examining streaming services’ compliance with the CCPA.

The Attorney General’s complaint (“Complaint”) centered on Disney’s targeted advertising … Read the rest