Updated December 4, 2025
The Court of Federal Claims has posted their Pre-Award Protest decision and rationale.
This is a pre-award protest brought by a protestor that did not bid on the solicitation. In such a case—in which there was no proposal or therefore no evaluation thereof—it is incumbent on the protestor to offer the Court some indication of the protestor’s capability to perform the contract and some indication that the errors alleged were indeed what kept the protestor from submitting a proposal. Rather than attempting to meet this standard through plausible factual allegations or perhaps a declaration attached to its complaint, Dev Tech simply offers the legal conclusion that it “is a prospective offeror with a direct economic interest in this procurement” in its complaint and several equally conclusory statements on the merits. ECF No. 1 ¶ 5. Dev Tech needed to do more. Although it is clear that aside from perhaps one of Dev Tech’s five protest grounds the agency did not err, without plausible factual allegations establishing standing, any analysis of the alleged errors would amount to an advisory opinion and allow this protest to become a “vehicle for the vindication of the value interests of concerned bystanders.” Therefore, the Court’s analysis will focus on Dev Tech’s general lack of standing and, additionally, its lack of standing as to each of the five counts of its complaint … For the reasons set forth, Dev Tech fails to establish that it has standing to bring this bid protest broadly or, more specifically, that it has standing to challenge any of the solicitation provisions for which it alleges error. Accordingly, the Court must dismiss Dev Tech’s complaint for lack of subject matter jurisdiction. The Clerk shall enter JUDGMENT accordingly.
You can read the full decision here.
Updated November 18, 2025
As OS AI reported last week, it appears that GSA has, at least for now, cleared a hurdle in their efforts to get this key GWAC awarded.
Bloomberg reported early this week that “Dev Technology Group Inc. lost its court protest challenging the contract bid requirements in the US General Services Administration’s Alliant 3 IT services procurement.
Dev’s complaint is dismissed for lack of subject-matter jurisdiction … The challenge to the procurement, which is worth $75 billion according to Bloomberg Government, said the solicitation’s requirement directing bidders to show experience with multiple federal customers was unreasonable, and unnecessary for meeting GSA’s needs….” The rest is behind a paywall.
Updated November 13, 2025
It is not apparent what next steps are, but (post shutdown) we do now have a better feel as to how the pre-award challenge may impact the competition for this important GWAC.
The latest word is that an Opinion and Order has been put forth to have the challenge dismissed for lack of subject matter jurisdiction.
This is likely to be happening because the court concluded it did not have the legal authority to review the issues raised.
More will be shared as it is made available.
Updated April 15, 2025
Details as to the grounds for the challenge remain limited, but we do now have a better feel as to how this may impact the timeline for an award on this recently submitted and important GWAC.
With respect to a voluntary stay, GSA agrees to voluntarily stay making awards for the Alliant 3 procurement up to and including November 1, 2025. The GSA will not stay any other aspect of the procurement, including evaluation of offers.
Dev Technology is not currently seeking any preliminary injunction in the case, so the agency can take all necessary steps to move forward with evaluation.
The tentative schedule shows a decision date that, barring extensive delays, will be decided well in advance of the November timeframe.
Updated April 11, 2025
Just days after word of a new Court challenge, the lone GAO protest has been dismissed.
Solicitation Number: 47QTCB24R0009
Agency: Federal Acquisition Service
Protester: Resource Management Concepts, Inc.
File number: B-423280.1
Outcome: Dismissed
Decision Date: Apr 11, 2025
Track Related GAO Activity Here
Updated April 10, 2025
The Due Date may be today, but if the early action is any indication the fight to be one of 76 awardees for this increasingly important GSA run GWAC will be fierce. See the latest on a new challenge below.
While a lone GAO protest remains open (see thread below), Dev Technology has put forth a formal challenge with the Courts protesting what it deems as certain unreasonable terms of the Solicitation that exceed the legitimate needs of the Agency.
Dev Technology, as a mid-sized other than small business concern, believes that they would possess a substantial chance of an award to a properly issued Solicitation that eliminates requirements that exceed GSA’s legitimate needs and that will likely and unreasonably prevent Dev Technology from obtaining the number of evaluated points necessary to be awarded a contract
- Dev Technology Group is respectfully requesting that this Court:
A. Declare that the terms of the Solicitation identified above are irrational, arbitrary,
and capricious, an abuse of discretion, contrary to law, and have no legitimate purpose for GSA;
B. Permanently enjoin GSA from proceeding with the evaluation and award of contracts based upon the current terms of the Solicitation; and - C. Require GSA to modify the Solicitation to eliminate terms that are unreasonable and serve no legitimate purpose of GSA, and provide a reasonable date for submission of final proposals
We will see if any of this carries water. More to be shared as it is made available.
The current version of the Solicitation was issued on March 12, 2025, with proposals due on April 11, 2025. – Alliant 3 GWAC, Request for Proposal (RFP)
