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Size Matters: Past Performance Rating Not Supported by Small Task Orders

Client Alert | 1 min read | 05.13.15

In sustaining the contractor's protest filed by C&M against the Air Force's $110 million award for F-15 support services, GAO held that the agency erred by (1) giving the awardee the highest past performance rating for prior delivery orders worth "only approximately 0.14 percent of the estimated value of the effort required by the RFP" and (2) failing to document how the awardee's other "$5.36 billion portfolio" bore any relevance to the services being solicited. In rejecting the agency's reliance upon tiny delivery orders and post hoc litigation arguments, GAO relied heavily upon its 2009 precedent in Health Net Fed. Services, LLC (also a C&M case), in which the agency attempted to defend its past performance evaluation based upon the awardee's general industry experience without any discussion of how that performance related to the services specified under the RFP.

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Client Alert | 4 min read | 11.18.25

DOJ Announces Major Enforcement Actions Targeting North Korean Remote IT Worker Schemes

On November 14, 2025, the U.S. Department of Justice (DOJ) announced a sweeping series of enforcement actions, including four guilty pleas and more than $15 million in civil forfeitures against the  Democratic People’s Republic of Korea (DPRK or North Korea) for remote information technology (IT) worker schemes. These actions underscore the federal government’s escalating focus on the exposure of U.S. companies to North Korean IT worker infiltration, following a series of U.S. Government action against the DPRK....