Professional Analysis, Inc. v. United States

CourtUnited States Court of Federal Claims
DecidedJune 3, 2025
Docket24-1897
StatusPublished

This text of Professional Analysis, Inc. v. United States (Professional Analysis, Inc. v. United States) is published on Counsel Stack Legal Research, covering United States Court of Federal Claims primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Professional Analysis, Inc. v. United States, (uscfc 2025).

Opinion

In the United States Court of Federal Claims No. 24-1897 Filed: May 23, 2025 † Published: June 3, 2025

PROFESSIONAL ANALYSIS, INC.,

Plaintiff,

v.

THE UNITED STATES,

Defendant,

and

CACI, INC.—FEDERAL

Defendant-Intervenor.

Thomas K. David, Reston Law Group LLP, Reston, VA, for the Plaintiff.

Matthew J. Carhart, Senior Trial Counsel, Commercial Litigation Branch, Civil Division, Douglas K. Mickle, Assistant Director, Patricia McCarthy, Director, and Brett A. Shumate, Acting Assistant Attorney General, U.S. Department of Justice, Washington, D.C. with T. Alexander Cloud, Jr., Assistant Counsel, Military Sealift Command, Norfolk N00L, for the United States.

Robert K. Tompkins, Holland & Knight LLP, Washington, D.C., with Kelsey M. Hayes, and Richard J. Ariel, for the Defendant-Intervenor.

MEMORANDUM OPINION AND ORDER

TAPP, Judge.

Good manners are not required in government contracting. Plaintiff, Professional Analysis, Inc. (“PAI”), asks this Court to adopt its construction of key terms of the Solicitation in

† This Opinion was originally issued under seal on May 23, 2025, (ECF No. 41). The Court provided parties the opportunity to submit proposed redactions. In a Joint Status Report filed May 30, 2025, (ECF No. 43), the parties indicated that no redactions were required. this bid protest, an invitation that this Court does not accept. All parties have moved for judgment on the administrative record based on their opposing interpretations of the words “shall,” “reservation,” “assumption,” and “qualification.” For the reasons stated below, the United States’ Cross-Motion for Judgment on the Administrative Record, (ECF No. 33), and Defendant-Intervenor’s Cross-Motion for Judgment on the Administrative Record, (ECF No. 34), are GRANTED. PAI’s Motion for Judgment on the Administrative Record, (ECF No. 32), is DENIED.

I. Background

This protest challenges a U.S. Department of the Navy, Military Sealift Command (“MSC”) award (Solicitation No. N3220523R4140 (“RFP” or “Solicitation”)) of a “Worldwide Logistics (WWL) Services” contract to Defendant-Intervenor, CACI–Federal, Inc. (“CACI”). (Compl. ¶¶ 1–2, ECF No. 1). The Solicitation was originally issued in 2023, seeking logistics support, material handling support, and supply chain management. (Administrative Record (“AR”) 8110–13, ECF No. 27). The RFP anticipated a fixed-price contract with a period of performance of a two-month phase-in period, a ten-month base period, and four twelve-month option periods. (AR 1708–1709).

The Solicitation stated that “[t]he evaluation process will use a Lowest Price Technically Acceptable (LPTA) evaluation approach in order to determine which offeror represents the best value to the Government.” (AR 1780–81). Proposals would be evaluated according to: Technical Approach (Factor 1), Past Performance (Factor 2), Price (Factor 3), and Small Business Participation Commitment Document (Factor 4). (AR 1780–83). Factor 1, Technical Approach, included three subfactors: (1) organizational experience; (2) understanding of sample problems 1, 2, 3, and 5; and (3) management approach and personnel experience. (AR 1781). As part of the Agency’s evaluation efforts, MSC would review each offeror’s small business subcontracting plan, and evaluate “the realism of the proposal.” (AR 1783). MSC amended the Solicitation six times. (See AR 1684). Solicitation Amendment 0006, (AR 1684–1817), issued in June 2024, is the final version of the Solicitation at issue. (Def.-Interv.’s Cross-MJAR at 2 n.1).

In addition to its many directions, the Solicitation contained an addendum to FAR 52.212-1, entitled “Additional Instructions to Offerors—Commercial Items” which provided general proposal instructions. (AR 1773). Specifically, the provision requested offerors to: “[p]lease provide certification that price was without reservation, assumption, or qualification and that the Total Evaluated Price contains pricing for all work in the [Performance Work Statement].” (AR 1778). In their proposal cover letter, offerors were directed to provide an “Agreement with Terms,” which would include:

A statement specifying the extent of agreement with all terms, conditions, and provisions included in the solicitation and agreement to furnish any or all services upon which prices are offered. Offerors are to clearly detail any exceptions taken and the rationale for the exceptions taken to the solicitation. Exceptions taken to the solicitation may render the proposal unacceptable to the Government.

(AR 1778–1779).

2 MSC first awarded the contract to PAI. (Compl. ¶ 12; AR 5318, 6596). CACI filed a protest with the Government Accountability Office (“GAO”), (GAO File No. B-422226.2), and MSC subsequently took corrective action and accepted revised proposals from both PAI and CACI, (Compl. ¶ 14; AR 7151–54).

MSC amended some of the instructions in the Solicitation as part of its corrective action. (See AR 1703 (“In taking corrective action, the Government revised the proposal instructions and evaluation criteria in an effort to clarify ambiguity.”). Most relevantly, MSC inserted a new introduction to the FAR 52.212-1 addendum, in addition to the guidance excerpted above:

Introduction: This FAR 52.212-1 addendum primarily sets forth proposal instructions, not evaluation criteria. The evaluation criteria for proposals submitted under this solicitation are set forth below in the FAR 52.212-2 provision. Moreover, although certain proposal instructions in this addendum establish minimum requirements pertaining to the length, format, and content of an Offeror’s proposal submission, and a proposal will be evaluated as Unacceptable if it fails to meet one of those minimum requirements, the majority of the proposal instructions in this addendum do not establish minimum requirements and are not evaluation criteria. In this FAR 52.212-1 addendum, the use of “shall” in a sentence denotes that the sentence establishes a minimum solicitation requirement. If “shall” is not used (e.g., “should” is used), then no minimum requirement is established.

(AR 8041 (red color in original)). Accordingly, MSC added “shall” to multiple provisions in the Amended Solicitation, (compare AR 6561 with AR 8046), but did not alter the text of the provision asking offerors to “[p]lease provide certification that the price was without reservation, assumption, or qualification and that the Total Evaluated Price contains pricing for all work in the PWS[,]” (Compare AR 6562 with AR 8046). Ultimately, the Source Selection Authority (“SSA”) determined CACI’s final proposal provided the best value to MSC and awarded CACI the contract. (AR 12722–25).

PAI protested at the GAO. (Compl. ¶ 6; GAO File No. B-422226.4). There, PAI presented two main arguments: first, that MSC improperly failed to conduct a price realism analysis, and second, that CACI’s proposal was technically unacceptable because it took exception to material provisions of the Solicitation. (AR 12911–19). The latter argument is also the focus of PAI’s Complaint here. (See generally Compl.). Given the strikingly similar arguments raised by PAI and MSC both at the GAO and in this forum, a review of the GAO proceedings is warranted.

At the GAO, MSC argued that the Solicitation did not contain “the imperative ‘shall’ in connection with the instruction to certify that the price was without ‘reservation, assumption, or qualification’ instead it ‘permissively requests offerors to provide the referenced certification.’” (AR 12884–85 (citing AR 1773)). MSC also argued that CACI’s proposal expressly stated that CACI took no exception to any terms, conditions, or provisions in the Solicitation and instead merely reserved a right to request an equitable adjustment under certain circumstances.

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