American Tech Solutions, LLC v. United States

United States Court of Federal Claims·Decided September 16, 2025·No. 25-685·Published

Opinion

In the United States Court of Federal Claims No. 25-685 (Filed under seal: August 12, 2025) (Reissued for Publication: September 16, 2025) 1

*************************************** AMERICAN TECH SOLUTIONS, LLC, * * Plaintiff, * * v. * * THE UNITED STATES, * * Defendant, * * and * * KNIGHT FEDERAL SOLUTIONS, INC., * * Defendant-Intervenor. * *************************************** David B. Dempsey, Dempsey Law, PLLC, Vienna, VA, counsel for Plaintiff. With whom was Ian Cronogue, Baker, Cronogue, Tolle & Werfel, LLP, McLean, VA, of counsel. Collin T. Mathias, U.S. Department of Justice, Civil Division, Washington, DC, counsel for Defendant. With whom was Major Joshua A. Reyes, Trial Attorney, United States Army Legal Services Agency, of counsel. Joseph M. Goldstein, Shutts & Bowen LLP, Fort Lauderdale, FL, counsel for Defendant- Intervenor. OPINION AND ORDER DIETZ, Judge.

American Tech Solutions, LLC (“ATS”) protests a decision by the United States Department of the Army (“Army”) to award a contract for information technology support services to Knight Federal Solutions, Inc. (“KFS”). ATS alleges that the Army made an improper award decision because KFS failed to meet the requirements of the solicitation and was therefore ineligible for award. ATS further alleges that the Army conducted an improper technical

1 This Opinion and Order was filed under seal on August 12, 2025, see [ECF 55], in accordance with the Protective Order entered on April 29, 2025, see [ECF 19]. The parties were given an opportunity to identify protected information, including source selection information, proprietary information, and confidential information, for redaction. The parties filed a joint status report on September 4, 2025, with agreed upon proposed redactions. [ECF 59]. The Court accepts all proposed redactions. evaluation of KFS’s technical proposal. For the reasons set forth below, the Court finds that the Army’s evaluation and award decision were reasonable and consistent with the solicitation criteria. Accordingly, ATS’s motion for judgment on the administrative record is DENIED, and the government’s and KFS’s respective cross-motions are GRANTED.

I. BACKGROUND

The Joint Readiness Training Center (“JRTC”) in Fort Johnson, Louisiana, provides the United States military with “relevant, rigorous, multi-echelon training . . . to develop adaptive leaders, confident units, and robust capabilities across the range of military operations achieving Army readiness.” AR 395. 2 On August 22, 2023, the Army issued a Request for Quote (“RFQ”) for JRTC Mission Support Services (“MSS”) using the ordering procedures for Federal Supply Schedules under Federal Acquisition Regulation (“FAR”) subpart 8.405. AR 210. 3 The Army intended “to award a Small Business (SB) Set-Aside Order under [the] General Services Administration . . . Information Technology Professional Services Multiple Award Schedule . . . for JRTC MSS requirements identified under [a] . . . Performance Work Statement (PWS).” Id. The RFQ contemplated a fixed price order consisting of a seven-month base period, four twelve- month option years, and a six-month option to extend services. AR 348.

Additionally, the RFQ stated that “[the] competitive source selection will be conducted using the Best Value Subjective Trade Off source selection process.” AR 388. The two evaluation factors were identified as “Factor 1: Technical,” and “Factor 2: Price.” Id. The RFQ explained that the technical factor was “significantly more important” than price but that “the award may not necessarily be made to the lowest priced offer[or] or the highest technically rated offeror.” Id. The RFQ cautioned offerors “that while the [Army] will not evaluate every PWS requirement for the purposes of the source selection evaluation, the awardee will be required to comply with all of the PWS requirements during task order performance.” Id. It further instructed that “the Offeror’s submission must convey to the [Army] that the Offeror is capable, possesses adequate technical expertise and experience, sufficient resources, and has the ability to plan, organize, and utilize those resources in a coordinated and timely fashion to meet the requirements of the . . . PWS.” Id. The solicitation outlined the “overarching evaluation approach” as follows:

a. Adequacy of Response. The submission will be evaluated to determine whether the offeror’s methods and approach have adequately and completely considered, defined, and satisfied the requirements specified in the RFQ. The submission will be evaluated to determine the extent to which each requirement has been addressed in the submission in accordance with the submission section of the RFQ.

2 The Court cites to the Administrative Record filed by the government on May 7, 2025, see [ECF 23], and made available to the parties electronically as “AR__.” 3 The RFQ issued on August 22, 2023, was amended following a question-and-answer period that concluded on August 29, 2023. AR 1204-05.

2 b. Feasibility of Approach. The submission will be evaluated to determine the extent to which the proposed approach is workable and the end results achievable. The submission will be evaluated to determine the extent to which successful performance is contingent upon proven devices and techniques. The submission will be evaluated to determine the extent to which the offeror is expected to be able to successfully complete the proposed tasks and technical requirements within the required schedule.

AR 389.

Regarding the technical factor, the RFQ stated that “[t]he [Army] will evaluate the contractor’s proposed plan to fulfill the requirements specified in the PWS, noting its associated merits and risks.” AR 389. The RFQ defined a merit as “[a]n offeror[’]s approach that provides the [Army] additional benefits that exceed the . . . requirement,” and defined a risk as “[a]n offeror[’]s approach that increases the probability of contract performance failure.” Id. Based on the technical evaluation, the Army would assign one of the following three ratings:

Id. Regarding the price factor, the RFQ stated that “the [Army] will evaluate the fixed price effort for reasonableness by conducting a price analysis.” AR 390. It further explained that the “Total Evaluated Price (TEP) will be the offerors’ proposed firm fixed priced effort and the Government provided cost (No Fee) estimate included in [the] . . . Cost/Price Workbook.” Id. The RFQ stated that “[t]he base program and all options will be included in the TEP for both evaluation and award purposes.” Id.

The Army received a total of seven offers, including the offers from ATS and KFS. AR 1207, 1587. KFS is listed as offeror B, and ATS is listed as offeror C. AR 1205. The technical evaluation team conducted an evaluation of each offeror’s technical proposal and “developed a consensus technical evaluation for each offeror,” identifying applicable merits and risks. AR 1206. ATS and KFS each received a “Good” rating. AR 1207. ATS received four merits and no risks. AR 1211-14. The evaluators concluded that ATS’s “technical proposal meets requirements and indicates a Superior approach, and [that] the risk of unsuccessful performance is low.” AR 1211. KFS received three merits and no risks. AR 1208-11. The evaluators similarly determined that KFS’s “technical proposal meets requirements and includes merits which indicate a Superior approach, and [that] the risk of unsuccessful performance is low.” AR 1208.

The price evaluation team conducted an evaluation of each offeror’s price proposal for reasonableness. AR 1221. The price evaluation did not result in an adjectival rating. Id. Since the planned order consisted of “a combination of firm fixed price [Contract Line Item Numbers (“CLINS”)] and cost type CLINS,” the evaluators “add[ed] the Contractor proposed Firm Fixed

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