Tracking the latest developments at the GAO and Court of Federal Claims
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In Island Creek Associates, LLC, B-423301.3 (Dec. 5, 2025), Island Creek Associates protested the Department of the Navy’s award to StraCon Services Group for program management contractor support services. Island Creek did not challenge any aspect of the Navy’s evaluation of proposals. Instead, its protest focused solely on alleged organizational and personal conflicts of interest related to StraCon’s subcontractor, Precise Systems, Inc., who was the incumbent contractor. Island Creek claimed that Precise gained an unfair competitive advantage from access to proprietary information and due to the involvement of a senior Navy official whose wife worked for Precise. GAO denied the protest in its entirety and provided a detailed analysis of conflict of interest law.

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In Chugach Logistics and Facility Services JV, LLC, B-423690 (Nov. 20, 2025​), CLFS protested an $80 million award by the Department of the Navy to CCS King George 2 LLC (CCS KG) for base operations support at Naval Base Coronado. CLFS alleged that the Navy unreasonably evaluated proposals under the corporate experience, past performance and price factors, and improperly failed to consider certain performance data that it claimed was “too close at hand.” GAO rejected all of CLFS’ challenges, finding that the Navy acted within its discretion and in accordance with the solicitation.​

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In National Energy Security Operations, LLC v. United States, U.S. Court of Federal Claims, No. 25-774 (Sept. 30, 2025, reissued Nov. 24, 2025), National Energy Security Operations, LLC challenged a $128 million Department of Energy (DOE) award to Strategic Storage Partners, LLC (SSP) for the management and operation of the Strategic Petroleum Reserve (SPR). The Court agreed with National Energy that DOE improperly applied unstated evaluation criteria in assessing the company’s Contractor Assurance System (CAS) approach, a rare such win on the merits. But National Energy’s broader protest failed because the Court concluded that this error did not affect the outcome. SSP’s proposal was simply too far ahead on the overall Management Approach factor, which was the most important evaluation factor. The decision provides a strong reminder that showing error is not enough, a protestor must also prove prejudice.

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In Marathon Targets, Inc. v. United States, U.S. Court of Federal Claims, No. 25-121 (Nov. 10, 2025, reissued Nov. 21, 2025), the Court of Federal Claims denied Marathon Targets Inc.’s request for a permanent injunction that sought to overturn the Marine Corps’ disqualification of Marathon and block performance of the awarded contract to MVP Robotics, Inc. Marathon, the incumbent, had been disqualified after the Marine Corps inadvertently disclosed protected source selection information to it, and Marathon failed to properly handle that information. Although the Court previously denied Marathon’s request for a preliminary injunction, this opinion resolves the case on the merits—and again sides with the agency. The Court found that the Marine Corps’ decision to disqualify Marathon was neither arbitrary nor capricious, and that Marathon lacked standing to challenge the award. The opinion also rejects each of Marathon’s evaluation-based claims against MVP’s proposal.

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In Hydraulics International, Inc. v. United States, U.S. Court of Federal Claims, No. 25-312 (Nov. 20, 2025), Hydraulics International, Inc. (HII) challenged the Army’s decision to award a sole-source contract for aviation ground power units (AGPU) and related services to Sun Test Systems, Inc. HII argued that the Army violated FAR Part 10 by failing to conduct meaningful market research and that HII was improperly excluded from consideration. While the Court agreed that the Army’s market research was deficient, it ultimately dismissed the protest for lack of standing, finding that HII could not deliver a compliant product in time and therefore could not have received the award. This decision is a rare one where the Court clearly disapproved of the agency’s actions, but still had to rule in the agency’s favor because the protester couldn’t get over the standing hurdle.

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In Advanced Management Strategies Group, Inc. v. United States, U.S. Court of Federal Claims, No. 25-695 (Nov. 20, 2025), Advanced Management Strategies Group, Inc. (AMSG) protested the Department of Energy’s award to Harkcon, Inc. for administrative support services related to nuclear material transport. AMSG alleged that Harkcon made a material misrepresentation by proposing its Chief Operating Officer as an on-site, full-time program manager in New Mexico, claiming that the representation was false and not credible because the individual was based in Virginia and already served as the program manager for two other active contracts. AMSG also requested to supplement the record with discovery and post-award declarations to support its claim. The Court rejected both the misrepresentation theory and the request for discovery. Notably, the Court emphasized the importance of sticking to the administrative record and relied heavily on admissions made by AMSG’s own counsel during oral argument.

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In Ernst & Young, LLP, B-423491.2 (Sept. 26, 2025), Ernst & Young (EY) protested the scope of corrective action taken by the Department of the Army following EY’s earlier protest of the Army’s award to Guidehouse for support of the Army Financial Improvement program. EY’s initial protest resulted in a voluntary corrective action, during which the agency announced it would reevaluate proposals and make a new award decision. However, during implementation of that corrective action, Guidehouse informed the Army that one of its proposed key personnel was no longer available. That development led the Army to open limited discussions focused on key personnel substitution, which in turn became the focus of EY’s follow-on protest.

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In SRM Group, LLC, B-423695 (Sept. 25, 2025​), SRM Group, the incumbent contractor, protested the Army’s award of a contract for lodging and transportation services at Camp Robinson to BryMak & Associates. SRM argued that the agency’s past performance evaluation was flawed and that the resulting best-value tradeoff was unreasonable. At the heart of the protest was SRM’s claim that BryMak’s past performance references did not merit the same “substantial confidence” rating that SRM received. SRM challenged the relevance of BryMak’s references, the inclusion of a subcontractor’s limited experience and the agency’s treatment of SRM’s own incumbent performance. GAO rejected each of these arguments, finding the evaluation well-documented and consistent with the solicitation.

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In Cosette Pharmaceuticals, Inc. v. United States, U.S. Court of Federal Claims, No. 25-cv-279 (Nov. 17, 2025), Cosette Pharmaceuticals protested the Department of Veterans Affairs’ decision to award a contract for the drug prasugrel to Golden State Medical Supplies. Cosette argued that the VA violated the Trade Agreements Act (TAA) because Cosette was the only offeror to submit a TAA-compliant proposal. Cosette manufactured its version of the drug in Germany, a compliant country under the TAA. By contrast, the awardee’s version of the drug was manufactured in India, a non-compliant country under the TAA.

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In QA Engineering, LLC, B-423716, B-423716.2 (Sept. 30, 2025​), QA Engineering protested the U.S. Army Corps of Engineers’ decision to award a contract for the construction of a pre-engineered metal building (PEMB) to Koman Advantage. QA argued that the agency improperly found its proposal technically unacceptable because it did not address quality control for off-site fabrication, a requirement it claimed was not clearly stated in the solicitation. QA also contended that its proposal did meet this requirement and that other offerors were treated more favorably despite submitting similar responses. GAO rejected all of these claims, finding that the solicitation clearly required an off-site fabrication quality control discussion, that QA failed to provide one, and that other offerors met the requirement. The protest also raised additional arguments regarding inconsistent evaluator scoring and consensus ratings, but GAO found no merit in those claims.

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