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The protester submitted a portion of its proposal late. The agency rejected the entire proposal. The protester argued the agency should have considered the proposal as submitted. But GAO found the incomplete proposal unacceptable.

RELYANT Global, LLC, GAO B-422475
  • Late FPR – After conducting discussions, the agency directed offerors to submit proposal revisions by 2 pm on March 14. The protester emailed it revisions in 6 separate emails. One of those emails, which contained price proposal notes, was sent four minutes after the 2 pm deadline. The agency excluded the entire proposal.
  • Material Information – The protester contended the agency should have considered its proposal without the missing price notes. GAO rejected the argument, finding the price proposal were a material part of the proposal. The solicitation clearly stated that failure to submit price notes could result in an unacceptable proposal.
  • Could the Agency Infer Missing Info? – The protester contended the agency could have evaluated the proposal as submitted and inferred the information on the missing pricing notes from other parts of the proposal. GAO rejected this argument, too. The pricing notes contained distinct information that could not be gleaned from other parts of the proposal.

The protester is represented by Jared Garceau. The agency is represented by John W. Cox of the Department of State. GAO attorneys Jungi Hong, Michael P. Grogan, and Evan D. Wesser participated in the decision.

–Case summary by Craig LaChance, Editor in Chief