Updated December 9, 2025
DIGEST
1. Request to dismiss post-award protest alleging that the awardee through its subcontractor has unmitigable organizational conflict of interests as untimely is denied where the agency had not conclusively communicated to offerors that the subcontractor was eligible to participate prior to the receipt of proposals.
2. Protest challenging alleged conflicts are denied where the agency’s investigation reasonably concluded either that no conflicts existed or that any conflicts were adequately mitigated, and the investigation gave meaningful consideration to all alleged conflicts.
DECISION
Island Creek Associates, LLC, a small business of Saint Leonard, Maryland, challenges the issuance of a task order to StraCon Services Group, LLC, a small business of California, Maryland, pursuant to request for proposals (RFP) No. N0042123R3014, issued by the Department of the Navy, Naval Air Systems Command (NAVAIR) under the Seaport NxG multiple award contract (MAC) seeking program management contractor support services for the Navy’s multi-mission helicopter program office. Island Creek alleges that StraCon should be disqualified from award because one of its subcontractors, Precise Systems, Inc., has multiple unmitigatable organizational conflicts of interest (OCIs) as well as a personal conflict of interest.
The protest is denied.
Protester: Island Creek Associates, LLC
Solicitation Number: N0042123R3014
Agency: Department of the Navy : Naval Air Systems Command
File number: B-423301.3
Outcome: Denied
Decision Date: Dec 5, 2025
Track Related GAO Activity Here
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