Eunsun Cho

Eunsun Cho is an associate in the Government Contracts Practice Group, where she advises clients on a range of regulatory and public policy matters, including federal procurement, supply chain security, and funding programs administered by the U.S. government. She also assists clients with M&A diligence and compliance investigations.

Eunsun maintains an active pro bono practice.

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Pentagon Releases Artificial Intelligence Strategy

By Nooree Lee, Stephanie Barna, Robert Huffman, Ryan Burnette, Krissy Chapman & Eunsun Cho on February 3, 2026

Posted in Artificial Intelligence (AI), Defense Industry, Procurement Reform

The past month has marked a series of announcements from the Department of War (the “Department”) emphasizing rapid deployment of artificial intelligence (“AI”) industry partnerships. These announcements signal opportunities for not only the defense industrial base, but also nontraditional defense contractors focused on technology and data.

On January 9, 2026, the Department released two key memoranda: (1) Artificial Intelligence Strategy for the Department of War, setting out measurable pace-setting projects, barrier removal authorities, and mandated data access; and (2) Transforming the Defense Innovation Ecosystem to Accelerate Warfighting Advantage, which aims to unify the defense innovation ecosystem under the Under Secretary of War for Research & Engineering as Chief Technology Officer (“CTO”).

Shortly after, on January 12, Secretary Hegseth delivered a speech, presenting an overhaul of the Department’s innovation and acquisition ecosystems.

The January 9 memoranda and Secretary Hegseth’s speech signal the Department’s intent to formalize a single, CTO-led innovation operating system designed to produce three outputs: next-generation technology, scalable products, and new ways of fighting—and to do it at “wartime speed,” with AI as the first major proving ground.

FY26 NDAA Aims to Raise the Dollar Thresholds for the Applicability of CAS and TINA

By Nooree Lee, Stephanie Barna, Peter Terenzio, Michael Pierce & Eunsun Cho on December 15, 2025

Posted in Congressional Action, Cost Accounting Standards, Defense Industry, Legislation, NDAA

Among the most challenging areas of regulatory compliance for federal contractors are cost accounting and cost and pricing data disclosure requirements. Indeed, many companies place guardrails on the nature and scale of their business relationships with the U.S. government precisely to avoid the application of these requirements. In a move that seems consistent with the federal government’s push towards expanding the defense industrial base and working with more commercial companies, Congress recently released the final negotiated language of the FY 2026 National Defense Authorization Act (“NDAA”). The draft text, currently awaiting a full Senate vote, contains impactful changes to reduce the applicability of federal Cost Accounting Standards (“CAS”) and the Truthful Cost or Pricing Data Statute (formerly the Truth in Negotiations Act, commonly referred to as “TINA”).

COFC Reaffirms Domestic Sourcing Regulations as a Viable Basis for Bid Protests

By Hunter Bennett & Eunsun Cho on December 9, 2025

Posted in Bid Protests, Buy American, Trade Agreements Act

Recently, in Cosette Pharmaceuticals, Inc. v. United States, the Court of Federal Claims sustained a bid protest, finding that the agency misapplied the Trade Agreements Act (“TAA”) during proposal evaluation. That decision is a helpful reminder that the Court can be a hospitable forum for challenging an agency’s application of domestic sourcing regulations.