Sole-Source Protest Win Nets Only Protest Costs
Client Alert | less than 1 min read | 12.08.05
In Europe Displays, Inc. (Dec. 5, 2005, http://www.gao.gov/decisions/bidpro/297099.pdf), GAO sustained a protest challenging a sole-source award under Simplified Acquisition Procedures because the agency’s justification was not objectively reasonable based on the information reasonably available to the agency, regardless of whether the agency had acted in good faith. However, because the contract had been fully performed by the time of the GAO decision, GAO awarded the protester only its protest costs, reasoning that the cost of responding to a FedBizOpps announcement of a proposed sole-source award, including preparation of a capability statement, is not a “proposal” cost for which GAO can recommend reimbursement.
Insights
Client Alert | 8 min read | 12.09.25
The Month in International Trade - November 2025
This news bulletin is provided by the International Trade Group of Crowell & Moring. If you have questions or need assistance on trade law matters, please contact Anand Sithian or Simeon Yerokun or any member of the International Trade Group.
Client Alert | 4 min read | 12.08.25
California’s AB 2013 Requires Generative AI Data Disclosure by January 1, 2026
Client Alert | 4 min read | 12.04.25
District Court Grants Preliminary Injunction Against Seller of Gray Market Snack Food Products
Client Alert | 21 min read | 12.04.25
Highlights: CMS’s Proposed Rule for Medicare Part C & D (CY 2027 NPRM)
