Crediting Awardee for Innovative Approach Not an Unstated Evaluation Criteria; COFC No. 15-1351C, McConnell Jones Lanier & Murphy LLP v. United States

Protest challenging the agency’s evaluation of technical proposals is denied, where the agency did not apply an unstated evaluation criteria by crediting the awardee for its innovation approach and where the agency reasonably concluded a minor difference between the awardee’s proposed staffing level and the government estimate to be insignificant; and protest challenging the agency’s cost realism analysis is denied, where the contracting officer reasonably attributed differences between the awardee’s proposed costs and the government estimate to the awardee’s technical approach.