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"//signed//" Doesn't Cut It

Client Alert | less than 1 min read | 04.30.08

A claim certification was invalid, and the ASBCA had no jurisdiction to decide the case, when the contractor's president submitted it by email and simply typed "//signed//" above his name. The Board in Teknocraft Inc. (Apr. 3, 2008) acknowledged that both the contractor and the government had used the typed designation "//signed//" in their emails during performance, but held that "//signed//" was not a "discrete, verifiable symbol of an individual" and constituted an "incurable defect" in the certification.

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Client Alert | 3 min read | 07.10.26

Federal Circuit Clarifies Application of Blue & Gold: Proposal Submission Deadline, Not Award, is the Operative Time for Filing

In Utech, Inc. v. United States, No. 24-1586 (Fed. Cir. June 24, 2026), the U.S. Court of Appeals for the Federal Circuit clarified that in most cases, a pre-award protest must be filed before the proposal submission deadline to avoid the Blue & Gold waiver rule.  This decision, while nonprecedential, is in line with U.S. Government Accountability Office (GAO) precedent, which has long held that pre-award protests must be filed before the proposal submission deadline....