The protester contended it should’ve received additional strengths under the technical factor. GAO didn’t agree. The protester had exceeded the solicitation’s requirements. Unfortunately, the protester’s proposal exceeded requirements in ways that didn’t benefit the agency. A strength is not warranted for merely exceeding requirements.
WorldWide Language Resources, Inc., GAO B-420900.3, B-420900.5
Background
The Army issued a solicitation seeking foreign language translation and transcription services. WorldWide Language Resources, Inc. and Valiant Government Services, LLC submitted proposals. The Army selected Valiant, finding that the firm’s higher-priced proposal offered distinct benefits. WorldWide protested.
Analysis
Additional Strengths
WorldWide alleged the Army failed to assign its proposal eight strengths under three technical subfactors. GAO didn’t think WorldWide deserved additional strengths. WordWide’s proposal exceeded the solicitation’s requirements. It didn’t exceed the requirements in a way that benefitted the agency.
Disparate Treatment
WorldWide further alleged the Army unequally evaluated proposals. WorldWide contended the Army assessed strengths to Valiant but didn’t assess strengths for similar benefits in WorldWide’s proposal. GAO found no disparate treatment. The differences in rating were based on differences between proposals. Valiant provided a better explanation for its approach.
WorldWide is represented by Anne B. Perry, Keely MaCarty, and Daniel J. Alvarado of Sheppard Mullin, Richter & Hampton LLP. The intervenor, Valiant, is represented by Daniel R. Forman, Christian N. Curran, Zachary H. Schroeder, and Issac D. Schabes of Crowell & Moring LLP. The agency is represented by Captain Jules L. Szanton, Major Nhu T. Tran, and Dana J. Chase of the Army. GAO attorneys Michael P. Grogan and Evan D. Wesser participated in the decision.
–Case summary by Craig LaChance, Senior Editor
