Agency Not Required to Use Any Specific Technique in Analyzing Unbalanced Pricing; IAP World Services, Inc. v. United States, COFC No. 20-1116CMay 18, 2021
Small Business that Earned 100% of Its Receipts from Another Company Was Not Economically Independent; Darton Innovative Technologies, Inc. v. United States, COFC No. 21-856May 18, 2021
Firm that Was Owned But Not Controlled by a Woman Not an Eligible WOSB; In the Matter of Joint Information Network, SBA No. WOSB-113May 18, 2021
Board May Lack Jurisdiction to Hear Claims Arising from Bill of Lading, But CBCA Finds It Has Jurisdiction Over Claim Alleging Breach of Agreement to Enter Bill of Lading; Vanguard Business Solutions v. Department of State, CBCA 6951May 17, 2021
Agency Had Discretion to Designate 8(a) Procurement as Follow-On, Rather than New, Requirement; Unami, LLC, GAO B-419601May 17, 2021
Protester Attempts to Use Late-Is-Late Rule as a Sword Against a Competitor (and Almost Succeeds), But Court Finds No Prejudice from Agency’s Acceptance of Late Proposal; KGL Food Service WLL v. United States, COFC No. 20-662CMay 14, 2021
Mere Suspicion of Fraudulent Claim Is Not Enough to Divest Board of Jurisdiction Over Appeal; Widescope Consulting and Contracting Services v. Department of Health and Human Services, CBCA 6895May 14, 2021
Agency Not Obligated to Look for Past Performance Information Protester Didn’t Submit; F-2 Solutions, LLC, GAO B-418950.2, B-418950.3May 14, 2021
DCMA Letter Expressing Some Thoughts About Unallowable Costs Was Not a Government Claim; Appeal of Northrop Grumman Corporation, ASBCA No. 62189May 14, 2021
GAO Is Cool with Agency Decision to Establish Single BPA Rather than Multiple BPAs; Active Deployment Systems, Inc., GAO B-419696May 13, 2021
No Disparate Treatment Where Protester and Awardee Had Same Quantity of “Good” Ratings, But Awardee Had Higher Quality Ratings; Blue Water Thinking, LLC; AcesFed LLC, GAO B-41961.9 et al.May 13, 2021
Agency Reasonably Limited “Interchanges” to Offerors that Had Potential to Provide the Best Value; PAE Aviation and Technical Services, LLC, GAO B-418828.3May 13, 2021
Protest Challenging Agency’s Conduct of Ongoing Corrective Action is Premature; Systems Implementers, Inc., GAO B-418963.4May 13, 2021
COFC Denies Motion to Dismiss Amazon’s Presidential Bias Theory in JEDI Protest; Amazon Web Services, Inc. v. United States, COFC No. 19-1796CMay 12, 2021
GAO Sustains Protest of FSS Task Order, Finds Awardee Offered Services Outside the Scope of Its FSS Contract; Deloitte Consulting, LLP, GAO B-419508, B-419508.2May 12, 2021
Although Ultimately Wrong, Agency’s Legal Position Was Reasonable When the Protest was Filed, So Protester Was Not Entitled to Costs; Brown Developments, LLC – Costs, GAO B-419279.2May 12, 2021
No Problem with Agency’s Bundling of Requirements; Roche Diagnostics Corporation, GAO B-419510, B-419510.2May 12, 2021
Agency Mislabeled the Solicitation But the Protester Waited too Long to Challenge the Error; US21, Inc., GAO B-419747May 12, 2021
In Stinging Rebuke to Bill & Ted’s Excellent Model of Proposal Drafting, GAO Finds Agency Reasonably Assessed Weakness to Proposal that Listed Dead Historical Figures—Johannes Gutenberg and Nickola Tesla—as Essential Personnel; Trilogy Federal, LLC, GAO B-418461.11, B-418461.18May 11, 2021
If the Solicitation Does Not Permit Proposal Revisions, the Agency Is Not Obligated to Conduct Discussions; Veteran Technology Partners III LLC, GAO B-418461, B-418461.20May 11, 2021