It Doesn't Have To Be Fancy

Reversing the trial court, the Federal Circuit in Industrial Door Contractors, Inc. v. U.S. (Sept. 22, 2006) upheld the sufficiency of a contract in which the government induced the bidder to dismiss its GAO protest by sending it a letter saying it was qualified to bid and asking, "Is this sufficient?" When the agency then disqualified the bidder, it breached this settlement agreement, irrespective of whether the bidder actually did qualify under the solicitation.