Kayhan Space Corp. v. United States
25-104 · cofc · 2026-06-08
Summary
In Kayhan Space Corp. v. United States, the Court of Federal Claims denied the protester's motion for judgment on the administrative record and granted the government's cross-motion, upholding the Air Force's refusal to make an SBIR award (Solicitation AFX 23.8) after national-security due diligence under the SBIR and STTR Extension Act of 2022 flagged the founders' ties to Iran and the IRGC. The court held the Air Force's non-selection was rational and procedurally compliant, applied heightened deference to a national-security risk determination, and rejected Kayhan's de facto debarment claim as unsupported, while allowing limited record supplementation only on the debarment issue. The decision illustrates how the enhanced SBIR national-security due-diligence regime is applied in a bid protest and the deference agencies receive on such security-based non-selection decisions.