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Michael G. Gruden, CIPP/G

Phone: +1 202.624.2545
1001 Pennsylvania Avenue NW
Washington, DC 20004-2595

Michael G. Gruden is an associate in Crowell & Moring's Washington, D.C. office where he is a member of the firm’s Government Contracts and Privacy & Cybersecurity groups. He possesses real-world experience in the areas of federal procurement and data security, having worked as a Contracting Officer at both the U.S. Department of Defense (DoD) and the U.S. Department of Homeland Security (DHS) in the Information Technology, Research & Development, and Security sectors for nearly 15 years. Michael is also a Certified Information Privacy Professional with a U.S. government concentration (CIPP/G).

Michael’s legal practice covers a wide range of counseling and litigation engagements at the intersection of government contracts and cybersecurity. His government contracts endeavors include supply chain security counseling, contract disputes with federal entities, suspension and debarment proceedings, mandatory disclosures to the government, prime-subcontractor disputes, and False Claims Act investigations. His privacy & cybersecurity practice includes cybersecurity compliance reviews, risk assessments, data breaches, incident response, and regulatory investigations. 

Government Contracts

Michael assists government contractors with federal contract compliance and administration matters throughout the contract lifecycle – from solicitation and award to audit, investigation, and termination. He advises clients on Federal Acquisition Regulations (FAR) provisions and clauses, as well as agency supplements such as the Defense Federal Acquisition Regulation Supplement (DFARS), Homeland Security Acquisition Regulations (HSAR), and others. He works closely with the Federal Service Desk and Defense Logistics Agency to resolve matters pertaining to entity registrations and subsequent changes to the System for Award Management.

Michael has counseled clients on a variety of government contracts issues including, but not limited to:

  • Conducted internal investigations of government contractors, addressing a variety of issues relating to government contracts and regulations.
  • Assisted clients in suspension and debarment matters and drafted comprehensive responses to notices of proposed debarment.
  • Represented government contractors in bid protests before the Government Accountability Office (GAO).
  • Advised government contractors regarding organizational conflicts of interest and post-government employment restrictions.


Michael has leveraged his procurement experience to advise numerous clients on DoD cybersecurity contract clauses. He has assisted clients in navigating the cybersecurity regulatory landscape by conducting compliance assessments, reviewing system security plans (SSPs) and plans of action and milestones (POAMs), and advising on Controlled Unclassified Information (CUI) marking guidance. Michael counsels clients on all aspects of cyber incident and data breach response, including working with forensic security consultants, conducting internal investigations, interacting with law enforcement, and complying with data breach notification laws. He also helps clients develop incident preparedness strategies and table-top exercises to assist companies in mitigating risks presented by data breach incidents.

Michael has counseled clients on a variety of data privacy and cybersecurity issues including, but not limited to:

  • Engaged in longstanding partnerships with multiple defense contractors to devise compliance strategies for DFARS 252.204-7012, including routine gap assessments and subsequent remediation plans.
  • Assisted major retailer with data breach notification reporting obligations and coordinated consumer and state notifications, as appropriate.
  • Helped clients assess and comply with cyber incident reporting obligations under DFARS 252.204-7012.
  • Conducted compliance assessments for clients and interpreted NIST SP 800-171 and NIST SP 800-53 regulatory requirements.
  • Advised clients on cloud service provider requirements under DFARS 252.204-7012 and DFARS 252.239-7010.
  • Counseled contractors regarding information security programs concentrating on Covered Defense Information (CDI), Controlled Unclassified Information (CUI), and Sensitive Security Information (SSI).

Government Experience

Michael’s extensive federal procurement experience allows him to uniquely counsel his clients with a real-world perspective concerning contract evaluation and administration, as well as cybersecurity compliance.

U.S. Department of Defense

  • Branch Chief for Information Technology and Physical Security Acquisitions at Washington Headquarters Services (WHS), a 4th Estate 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:
    • $500M 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 their advance staff.
    • Travel agreements for the Secretary of Defense’s 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 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 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).

U.S. 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, Michael worked to:
    • Lead 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.
    • Administer Broad Agency Announcement (BAA) solicitation encompassing all program missions within S&T. Engaged with industry regarding the BAA, liaised between industry, members of Congress, the Executive Director of S&T, and program offices.
    • Award cybersecurity and CBRNE contracts for S&T and HSARPA.
    • Partner with the Office of Security to award essential IT software and hardware contracts.

Michael earned his law degree from Georgetown University Law Center, where he was an editor of the Journal of National Security Law & Policy.


  • Virginia Commonwealth University, B.A., magna cum laude with University Honors
  • Georgetown University Law Center, J.D.


Admitted to practice: District of Columbia, New York

View More

"Accounting Cost & Pricing Compliance and Pitfalls," Government Contracts Breakfast Series, Herndon, VA (September 18, 2019). Presenters: Nicole Owren-Wiest, Elizabeth Buehler, Charles Baek, Michael G. Gruden, and Catherine O. Shames.
"Defending Cybersecurity False Claims Act Allegations," Bloomberg Law (September 18, 2019). Authors: Jason M. Crawford, David B. Robbins, Kate M. Growley, and Michael G. Gruden.
"Cybersecurity Maturity Model Matures: DoD Adds New Requirements to Draft Cybersecurity Certification," Government Contracts Bullet Points (September 10, 2019). Contacts: Kate M. Growley, CIPP/G, CIPP/US, Evan D. Wolff, Maida Oringher Lerner, Michael G. Gruden, CIPP/G
Client Alert/Newsletter
"Supply Chain Perspectives — Connecting the Dots on Supply Chain Security and Risk Management," Government Contracts Bullet Points (August 22, 2019). Contacts: Peter Eyre, Adelicia R. Cliffe, Kate M. Growley, CIPP/G, CIPP/US, Judy Choi, Paul Freeman, Michael G. Gruden, CIPP/G
Client Alert/Newsletter
"Under the Wire: FAR Council Announces Interim Rule to Implement NDAA Procurement Ban on Huawei and Other Chinese Telecommunications Equipment," Government Contracts Bullet Points (August 13, 2019). Contacts: Adelicia R. Cliffe, Paul Freeman, Alan W. H. Gourley, Kate M. Growley, CIPP/G, CIPP/US, Michael G. Gruden, CIPP/G
Client Alert/Newsletter
"Uncontrolled Information: DoD Audit Finds Contractor Lapses in Protecting Controlled Unclassified Information ," Government Contracts Bullet Points (August 2, 2019). Contacts: Kate M. Growley, CIPP/G, CIPP/US, Evan D. Wolff, Maida Oringher Lerner, Michael G. Gruden, CIPP/G
Client Alert/Newsletter
"DCMA Revises Cyber Supply Chain Review: Updated Guidebook Modifies Audit Standards," Government Contracts Bullet Points (July 16, 2019). Contacts: Evan D. Wolff, Nicole Owren-Wiest, Maida Oringher Lerner, Kate M. Growley, CIPP/G, CIPP/US, Michael G. Gruden, CIPP/G
Client Alert/Newsletter
"These Are a Few of Our Favorite IoT: NIST Finalizes Internet of Things Cyber Guidance," Government Contracts Bullet Points (July 2, 2019). Contacts: Kate M. Growley, CIPP/G, CIPP/US, Cheryl A. Falvey, Evan D. Wolff, Peter B. Miller, CIPP/G/US/E, CIPM, CIPT, Michael G. Gruden, CIPP/G
Client Alert/Newsletter
"Double Whammy: NIST Unveils Draft Enhanced Security Requirements and Revisions to NIST SP 800-171," Government Contracts Bullet Points (June 21, 2019). Contacts: Kate M. Growley, CIPP/G, CIPP/US, Evan D. Wolff, Maida Oringher Lerner, Michael G. Gruden, CIPP/G
Client Alert/Newsletter
"DoD Previews New Third-Party Cyber Certification Requirements," Government Contracts Bullet Points (June 17, 2019). Contacts: Evan D. Wolff, Maida Oringher Lerner, Kate M. Growley, CIPP/G, CIPP/US, Michael G. Gruden, CIPP/G
Client Alert/Newsletter

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