Alluviam, LLC v. United States
16-614 · cofc · 2016-09-16
Summary
In Alluviam, LLC v. United States, the Court of Federal Claims dismissed a post-award bid protest challenging the Navy/CTTSO's use of Broad Agency Announcements to fund development of hazardous-materials decision-support software awarded to Georgia Tech Applied Research Corporation. The court held the protester lacked standing as an interested party (it had no substantial chance of award and was really attacking the agency's chosen procurement method), had waived its objections under Blue & Gold Fleet by not raising them before proposals closed, and that the protest was moot because the challenged contracts were essentially complete. The decision illustrates the standing, waiver, and timeliness limits on challenging an agency's choice to use a BAA-style research-and-development acquisition method.