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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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In Castro & Company, LLC, B-423689, (Nov. 13, 2025), ​Castro & Company protested the Federal Election Commission’s (FEC) decision to award a blanket purchase agreement (BPA) to Contracts Management Enterprises (CME) for financial management and accounting support services. Castro argued that CME had an unmitigable impaired objectivity organizational conflict of interest (OCI) because one of CME’s employees worked as a contract specialist on a separate FEC contract where she was in close proximity to the source selection authority for the protested procurement. The protester also challenged multiple aspects of the agency’s technical evaluation, including findings that its proposal lacked “timeline details” and a “structured response,” both of which Castro contended were not supported by the solicitation or adequately explained by the agency. Finally, Castro asserted that the agency’s best-value tradeoff was flawed because the FEC failed to consider Castro’s lower-priced quotation when selecting among technically acceptable offerors. GAO sustained the protest, finding that the agency failed to meaningfully investigate or document the alleged OCI, that the technical evaluation was unsupported, and that the tradeoff analysis improperly omitted consideration of Castro’s quotation.

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In Bowhead Enterprise, Science and Technology, LLC v. United States, U.S. Court of Federal Claims, No. 24-2110C (Nov. 5, 2025), Bowhead challenged the Army’s award of a systems engineering and program management contract to DNI Emerging Technologies, raising a host of claims including: an unmitigated organizational conflict of interest (OCI), flaws in the agency’s post-award OCI investigation, unfair comparative technical evaluations, erroneous past performance ratings and a flawed best-value tradeoff. The protest also alleged that DNI’s proposal relied solely on subcontractor past performance and that Bowhead’s ratings were unreasonably low despite being the incumbent. The Court denied all claims, reinforcing several key principles of protest law.

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In Active Deployment Systems, LLC v. United States, U.S. Court of Federal Claims, No. 25-968C (Oct. 30, 2025), Active Deployment Systems (ADS) challenged several aspects of the Department of Homeland Security’s (DHS) award of 42 indefinite delivery /indefinite quantity (IDIQ) contracts for detention related services under a solicitation issued by Immigration and Customs Enforcement (ICE). ADS alleged that ICE violated the terms of the solicitation by awarding far more contracts than advertised, and that the solicitation’s pricing structure—which included fixed price caps—was irrational and arbitrary. ADS sought to halt the award of any task orders and urged the Court to find that it had been competitively harmed by the agency’s actions. But the Court disagreed, finding no violation of the solicitation and, most notably, no prejudice, even assuming ADS’ complaints about the competition had merit.

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In United Aero Group, LLC v. United States, U.S. Court of Federal Claims, No. 25-248 (September 29, 2025), United Aero Group, LLC challenged the Department of State’s decision to direct AAR Government Services, Inc. to perform helicopter maintenance work at a Florida facility under an existing task order. United Aero argued that the agency had violated both the Competition in Contracting Act (CICA) and the Rule of Two by assigning the work to AAR without opening it to competition or reserving it for small businesses. The Court, however, found that it lacked jurisdiction over the protest, and that the Rule of Two did not apply to the agency’s technical direction under the task order.

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