Proof Of Actual Bias Not Required To Show Conflict Of Interest
Client Alert | 1 min read | 12.07.06
Using the rarely-invoked exception to its timeliness rules for protests raising issues of widespread interest to the procurement community, the GAO in Celadon Laboratories, Inc., (http://www.gao.gov/decisions/bidpro/ 298533.pdf, Nov. 1, 2006) upheld a protest challenging an HHS decision not to fund the protester’s Small Business Innovation Research proposal, finding a conflict of interest where the members of the Special Emphasis Panel (SEP) that evaluated (and rejected) the proposal were employed by, or funded by, firms that support a competing technology. Because of the specific conflict information protester brought to the agency’s attention during the evaluation, GAO not only rejected HHS’s reliance on its SEP’s self-certification but also, rejected the argument that actual bias must be shown and instead concluded that in cases in which the evaluator has a conflict, prejudice is presumed.
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Client Alert | 2 min read | 04.10.26
On April 7, 2026, six federal agencies (FBI, CISA, NSA, EPA, DOE, and U.S. Cyber Command – Cyber National Mission Force) published a joint advisory warning that Iranian-affiliated threat actors are targeting internet-facing OT devices, particularly PLCs. In some cases, the threat actors have caused operational disruptions and financial losses at U.S. critical infrastructure organizations by manipulating software files that contain configuration settings as well as showing false data on hardware and software dashboards and displays.
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OMB Issues New Policy on Federal IT Transparency and Acquisition Oversight
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Preserve It or Lose It: A Missing Jury Instruction Costs Columbia University $94M in Damages
