SaiTech, Inc. v. Venesco, LLC

Court of Appeals of Virginia·Decided August 18, 2026·No. 0606254·Unpublished

Opinion

COURT OF APPEALS OF VIRGINIA Record No. 0606-25-4

SAITECH, INC.

v.

VENESCO, LLC

Present: Judges Raphael, Lorish and Frucci Argued at Arlington, Virginia Opinion Issued August 18, 2026*

FROM THE CIRCUIT COURT OF FAIRFAX COUNTY Michael F. Devine, Judge

David E. Murphy (Laura Golden Liff; Matthew L. Devendorf; McCandlish & Lillard; Miles & Stockbridge P.C., on briefs), for appellant.

Matthew E. Feinberg (L. Akinyi Orinda; Todd M. Reinecker; PilieroMazza PLLC, on brief), for appellee.

MEMORANDUM OPINION BY

JUDGE STEVEN C. FRUCCI

SaiTech, Inc., sued Venesco, LLC, alleging breach of the agreed division of work in their joint venture, Venesco & SaiTech Joint Venture, LLC (“Joint Venture”), and fraudulent misrepresentation regarding how the work would be divided. Following a bench trial, the circuit court ruled in Venesco’s favor on both counts. On appeal, SaiTech contends that Venesco breached the Joint Venture agreement (the “Agreement”), which SaiTech argued required a specific allocation of work. Finding no error, we affirm.

*

This opinion is not designated for publication. See Code § 17.1-413(A).

BACKGROUND1

Under familiar appellate principles, the evidence is summarized in the light most favorable to the prevailing party at trial, Venesco. See Moncrieffe v. Deno, 76 Va. App. 488, 496 (2023).

SaiTech and Venesco are companies with experience in competing for and servicing federal government contracts. SaiTech previously participated and successfully graduated from the Small Business Administration (SBA) 8(a) Business Development Program,2 and it had about 185 employees in 2017. Due to its size, SaiTech no longer qualified as an 8(a) certified small business. In contrast, Venesco was a certified SBA 8(a) small business, engaging mostly in administrative general consulting and seeking to grow into IT consulting.

In 2017, SaiTech and Venesco negotiated the Agreement, hoping to win the bid for the NASA Headquarters Information Technology Support Services Contract (the “Prime Contract”). The Prime Contract was an SBA 8(a) set-aside contract, so NASA would award the contract to the SBA, which then would issue the award to the most competitive 8(a)-eligible offeror. Subject to compliance with SBA regulations, an 8(a)-qualified small business could enter a joint venture with a non-8(a) firm to compete for awards.

To comply with “SBA policies and regulations,” the parties drafted the Agreement and submitted it to the SBA for approval. The SBA required certain mandatory terms in the Agreement, including that the 8(a) participant must: (a) be manager; (b) administer contract performance; (c) own at least 51% of the joint venture; and (d) receive profits at a rate at least

1 The record is partially sealed. “To the extent that this opinion mentions facts found in the sealed record, we unseal only those specific facts, finding them relevant to the decision in this case. The remainder of the previously sealed record remains sealed.” Levick v. MacDougall, 294 Va. 283, 288 n.1 (2017).

2 The purpose of the 8(a) program is to help small and disadvantaged businesses compete in the American economy through business development. 13 C.F.R. § 124.1.

equal to the amount commensurate with the work it performs. See 13 C.F.R. § 124.513(c). SBA regulations required the 8(a) participant to perform “at least 40% of the total done by all partners,” and the 8(a) participant’s share must be substantive and not just administrative. 13 C.F.R. § 124.513(d)(2). In addition, a joint venture agreement must include a general description of anticipated responsibilities, “including ways that the parties to the joint venture will ensure that the joint venture and the 8(a) partner(s) to the joint venture will meet the performance of work requirements.” 13 C.F.R. § 124.513(c)(7).

The Joint Venture’s 2017 proposal letter stated that the “Joint Venture will perform at least 60% of the work on its own and will subcontract only the work, which requires specialized set of skills not within Venesco or SaiTech capability.” It included reference to three teaming partners, which would be subcontractors to the Joint Venture partners, given their unique skills. The proposal’s cost volume anticipated about 33% of the work going to the teaming partners and more than 66% to the joint venturers. There would also be “Other Direct Cost” (ODC) contractors, and the joint venturer managing the ODC contractors would earn a markup.

The parties executed the first Agreement in 2017, and re-executed it in 2018, at SBA’s request for minor revisions. The Agreement formed the Joint Venture, which sought to serve as the prime contractor for task orders awarded under the Prime Contract. The Joint Venture lacked its own direct employees. Under the Agreement, Venesco would be the Managing Venturer of the Joint Venture, and SaiTech would be the Partner Venturer.

Section 14 of the Agreement titled “Performance of Work” provided:

For any 8(a) contract, including those between mentors and protégés authorized by 13 C.F.R. § 124.520, the Joint Venture must perform the applicable percentage of work required by 13 C.F.R. § 124.510. As such, the performance of work will be as follows:

The Managing Venturer will perform Project Management, Project Financial Control. The Partner Venturer will perform Recruitment, Training, Technical Expertise.

The Managing Venturer will perform at least forty five percent (45%) of the work performed by the Joint Venture and Partner venture will not perform more than fifty five percent (55%).

In December 2017, the SBA requested that the Joint Venture provide more information before the Joint Venture could be approved as an 8(a) certified entity. In response to that request, SaiTech produced a document named “List of Work Share by Labor Category and Firm,” which showed “significant overlap” in the type of work that SaiTech and Venesco would perform. The list showed that both companies would provide labor in 15 general categories, Venesco solely would provide labor in 5 categories, and SaiTech solely would provide labor in 6 categories. The list was inconsistent with the labor categories in the Agreement’s Section 14 because it did not exclusively allocate “Recruitment, Training, [and] Technical Expertise” to SaiTech or exclusively allocate “Project Management[ and] Project Financial Control” to Venesco.

NASA awarded the Prime Contract to the Joint Venture in 2019. NASA directed the Joint Venture to engage certain vendors during the transition away from the incumbent contractor. During the project’s transition, SaiTech’s vice president (VP) served as bid-transition manager. He worked to ensure “continuity of operations” by reaching out and employing 150 existing NASA employees. The VP also engaged about 20 third-party specialized vendors, most of whom were already working for a prior NASA contract and had special skills. SaiTech emailed Venesco that these vendors “[b]asically . . . will be ODC subs.” NASA directed that most of these vendors be billed as ODCs.

NASA originally had estimated that these ODCs would cost about $14.1 million—a figure that the Joint Venture included in its proposal. As managing partner, Venesco processed and paid all ODCs under the Joint Venture, as part of its responsibility for contract administration, and it

added general and administrative costs to the ODC invoices. The Joint Venture’s proposal-cost volume had stated that all ODCs would be “proposed as being procured through JV Member, Venesco LLC.” SaiTech did not administer (as opposed to manage) the ODCs.3 When SaiTech sought clarification about ODCs, the SBA advised that ODCs were part of contract administration and “not part of workshare,” and certain vendors were billed as ODCs as NASA requested, but vendors were not subcontractors. A 2017 email indicated that Venesco told SaiTech that the 45% minimum percentage applied “on labor,” but did not include ODCs.

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SaiTech, Inc. v. Venesco, LLC, (Va. Ct. App. 2026).

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