Articles Posted in Organizational Conflict of Interest (OCI)

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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 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 Peraton Inc., B-423639 (September 17, 2025), Peraton Inc. protested the General Services Administration’s award of a task order to General Dynamics Information Technology (GDIT) for IT lifecycle support services at U.S. Strategic Command. Peraton challenged several aspects of the agency’s evaluation and award decision. It argued that the agency had applied unstated evaluation criteria by placing excessive emphasis on audiovisual (A/V) engineering support requirements that were not clearly highlighted as evaluation factors. Peraton also claimed that the agency improperly double-counted weaknesses, penalizing the same alleged deficiency in both the technical and staffing evaluation areas.

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Emissary LLC, the incumbent contractor, protested the Department of Defense’s Washington Headquarters Services’ award of a contract to Gemini Industries for technical support services to the Office of the Assistant Secretary of Defense for Special Operations/Low-Intensity Conflict. (See emissary LLC, B-422388.3, et al., July 29, 2025.) GAO sustained the protest, finding that the agency conducted a flawed technical evaluation, improperly credited past performance, and failed to evaluate the impact of an OCI mitigation plan that altered the awardee’s technical approach. This is a rare case where a protester prevailed on both evaluation and organizational conflict of interest (OCI) grounds, offering a roadmap for what can go wrong when agencies rush or overlook key details in an awardee’s proposal.

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