Tracking the latest developments at the GAO and Court of Federal Claims
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In Advantaged Solutions, Inc. v. United States, U.S. Court of Federal Claims, No. 25-1806 (Jan. 30, 2026), Advantaged Solutions, Inc. (ASI) protested the Defense Logistics Agency’s decision to rescind an initial award to ASI and instead award a $130 million SAP enterprise resource planning (ERP) services contract to Oakland Consulting Group. The procurement involved software upgrades to DLA’s ERP platform. After initially finding Oakland technically unacceptable and awarding to ASI, DLA discovered that evaluators had treated identical proposal language differently in assessing the offerors’ Hybrid Agile methodology. DLA issued a stop-work order, reevaluated the proposals, found both technically acceptable and awarded to Oakland as the lowest-priced technically acceptable offeror.

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In Marvin Test Solutions, Inc., B-423928; B-423928.2 (Jan. 28, 2026), Marvin Test Solutions filed a pre-award protest challenging the Department of the Air Force’s RFP for a common armament tester (CAT-F) system for F-15, F-16 and A-10 fighter aircraft. Marvin argued that the agency was required to conduct the procurement as a commercial item acquisition under FAR Part 12 and that the solicitation was unduly restrictive of competition, particularly with respect to a minimum screen size requirement for the handheld operational-level (O-level) tester.

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In Centerline Logistics Corporation, B-423838, et al. (Jan. 7, 2026), Centerline Logistics Corp. protested the Air Force’s award of a roughly $200 million fuel transportation services contract to Vane Line Bunkering. Centerline challenged multiple aspects of the evaluation and source selection decision, arguing that the agency applied unstated evaluation criteria, treated offerors disparately, failed to consider negative information “too close at hand,” and did not conduct meaningful discussions regarding the relevance of Centerline’s past performance. GAO denied the protest in its entirety. In doing so, the decision serves as a useful refresher on several important protest doctrines—and the high bar protesters must clear to prevail in a GAO protest.

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Twice in one week, GAO dismissed bid protests as untimely, with each case highlighting a different but equally unforgiving timeliness trap. In ASG Solutions Corp., B-424053 (Jan. 16, 2026), the protester mistakenly assumed it was entitled to a FAR Part 15 debriefing in a FAR Part 13 procurement, incorrectly believing that its protest clock had been tolled. In Mission Analytics, LLC, B-423980 (Jan. 14, 2026), the protester miscalculated the deadline for filing a follow-on GAO protest after initial adverse agency action, and missed the filing deadline by one minute. Together, the decisions underscore GAO’s strict enforcement of its timeliness rules and serve as a reminder that misunderstandings about debriefings, agency-level protests and filing deadlines are often fatal to otherwise potentially successful protest challenges.

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In Manutek Inc., B-423476.2, et al. (Jan. 1, 2026), Manutek protested the National Oceanic and Atmospheric Administration’s decision not to award it an IDIQ contract for professional, scientific and technical services under the ProTech 2.0 Weather Domain. The protest focused largely on the agency’s evaluation of Manutek’s oral presentation, including alleged flaws in time management, documentation, evaluator judgments and the conduct of the post-presentation interactive dialogue.

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In Markon LLC, B-423767, et al. (Dec. 12, 2025), Markon protested the Central Intelligence Agency’s award to Arcfield for business operations, IT engineering and business enterprise modernization support. Markon challenged the CIA’s cost realism evaluation, arguing that the agency improperly relied on oral instructions given during pre-solicitation industry one-on-one sessions, instructions that were never incorporated into the final RFP. According to Markon, the CIA used those oral statements to reject Markon’s proposed efficiencies and imposed a significant upward cost adjustment instead of evaluating whether Markon’s proposed costs were realistic for its unique technical approach. GAO sustained the protest, finding that the CIA evaluated proposals using unstated criteria and failed to conduct the cost realism analysis required by the solicitation and procurement regulations.

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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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