Qualifying Language Renders Defective Claim Submitted on Behalf of Subcontractor; CBCA 5942, Development Alternatives Inc. on behalf of ERSM (Afghanistan) Limited d/b/a Edinburgh International v. U.S. Agency for International Development

Appeal of the deemed denial of a claim submitted on behalf of a subcontractor is dismissed for lack of jurisdiction, where the initial submission included qualifying language mitigating the contractor’s certification of the accuracy of the subcontractor’s claim, and where the contractor could not cure this defect by submitting a properly certified claim during proceedings, because the insertion of the qualifying language was an intentional defect.