The USPS had an interagency agreement under the Economy Act with the Equal Employment Opportunity Commission for postage. Under the IAA, USPS used Auctane (stamps.com) to supply the postage for the EEOC. When the government cut a purchase order to Auctane without competition, Pitney Bowes protested. But, here, apparently, the EEOC's use of a purchase order was not for new services, but instead "to effectuate payment of goods (postage) obtained through the IAA." That's because, previously, a "technical error with the platform prevented the payment of postage from being deducted from the EEOC's account," and the purchase order was intended to cover that cost. As a result, the GAO rejected Pitney's claim because it had "no basis to question the propriety of the IAA."
Air Force sought out a "common armament tester for F-15, F-16, and A-10 fighter aircraft." Protestor's product did not meet the Air Force's minimum requirements. For example, the protestor's screen was too small. Accordingly, the GAO concluded that the protestor was not an interested party and dismissed the protest.
GAO: Marvin Test Solutions, Inc., B-423928,B-423928.2 (Jan 28, 2026)
Agency requested that vendors include "pre-priced, and non-pre-priced, coefficients for each performance location" as part of vendors' pricing proposals. One of the vendors, however, in the pricing spreadsheet didn't provide coefficients, it provided the full total within the proposal. On protest, that vendor argued that "because it made an obvious error in its pricing proposal, the agency should have afforded the firm an opportunity to correct its mistake." GAO disagreed, noting its longstanding view that seeking clarifications is an option, not an obligation. Protest denied.
GAO: Diversified Maintenance Systems, Inc., B-423945,B-423945.2 (Jan 29, 2026)
Protestor challenged a $1.3 billion sole-source contract by the Forest Service. GAO found, however, the protestor was not an interested party because it didn't (yet) sell a product that was on the qualified product list. Protest dismissed.
GAO: Coulson Aviation USA, Inc., B-423952,B-423952.3 (Feb 04, 2026)
The Air Force solicited proposals for "training intelligence plans and exercise support for cyber readiness operations and weapons and tactics network defensive operations" and made an award to Cherokee Nation Strategic Programs, LLC (CNSP). Protestor argued that the Air Force evaluation of its proposal was unreasonable, but GAO found that the record supported the agency's evaluation. Protestor also argued that CNSP's cost was unrealistic because the agency used an "arbitrary" floor of 15% below incumbent labor rates. GAO rejected the argument, finding credible the agency's explanation that the 15% floor was "based on the collective experience of the evaluation team to determine whether a proposed labor rate was unrealistic and could present a risk to program success." GAO also rejected protestor's claim of unequal discussions and found that the agency's best-value tradeoff was documented and reasonable. Protest denied.
On May 5, 2025, the COFC issued an injuction to the Army to "conduct a new evaluation of the offerors’ initial proposal submissions in accordance with the Solicitation." In September 2025, the Army decided to amend the Solicitation and requested revised proposals. The protestor argued that this decision violated the court order, and the court agreed: "the Court holds that the Army’s actions achieved the same result that the injunction forbade: evaluating altered proposals beyond those included in the initial proposals." Permanent injunction issued.
COFC: Gemini Tech Services LLC v. United States, 24-1494 (Feb 5, 2026)
Agency found protestor's proposal to be non-responsive because the protestor did not include the required documentation for its personnel as part of the offer. Protestor claimed that the proposed personnel was a contractor, not a current employee, so no documentation was required. But the agency and GAO disagreed based on the plain language of the solicitation.
GAO also rejected protestor's claim that the agency needed to refer the protestor's disqualification to the SBA for a Certificate of Competency. But, GAO noted that the agency disqualification was based on the proposal's deficiencies, not on a non-responsibility determination.
Protest denied.
Protestor argued, without any evidence, that an awardee was not a SDVOSB. SBA found that the protestor "utterly fail[ed] to make any specific allegations that [the awardee] is not in compliance with the regulations." Protest denied.
