'Page-Count' Method Supports Claim For Reimbursement Of Protest Costs

Aug.17.2006

Despite the agency's blanket objections to almost all of a prevailing protester's claimed costs, the Government Accountability Office ("GAO") in BAE Technical Services, Inc. - Costs , B-296699.3 (Aug. 11, 2006), http://www.gao.gov/decisions/bidpro/2966993.pdf, held that the protester was entitled to recover costs attributed to almost all of the issues raised as they are "largely intertwined parts of [its] basic objection that the [agency] misevaluated proposals and treated offerors unequally." Although the records of the time spent on the protest were not detailed enough to attribute time on an issue-by-issue basis, GAO relied on the application of a "page-count" method to conclude that approximately 94.5 percent of the number of pages in submissions to GAO were devoted to issues related to the meritorious protest allegations.

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