Inkit Inc. (B-423724)

You should not care.

Category: SBIR, standing

Date: 9 September 2025

URL: https://www.gao.gov/products/b-423724

Inkit, an SBIR program participant, protested after the Army issued a $43,342 task order to Carahsoft for DocuSign software licenses under the Army's Computer Hardware Enterprise Software and Solutions program. Inkit argued the Army was required to consider SBIR phase III commercialization and award the contract to Inkit based on its prior SBIR research and development work, and that the Army improperly specified a brand name product.

GAO dismissed Inkit's assertion that the SBIR Policy Directive required the Army to conduct the procurement as a phase III award. While the directive mandates phase III awards when agencies pursue research or production of technology developed under SBIR, Inkit failed to establish any connection between its four prior SBIR projects and the DocuSign software being acquired. The protest provided no meaningful discussion linking the protester's prior work to the task order requirements.

Further, GAO found Inkit lacked standing to protest because it does not hold a CHESS contract. The Army Federal Acquisition Regulation Supplement designates CHESS as the mandatory source for commercial IT hardware and software purchases. Because Inkit would not be eligible to receive an award under the mandatory source provision, it does not qualify as an interested party.

The protest was dismissed on multiple grounds: insufficient factual basis for the SBIR claim, lack of interested party status, and absence of GAO jurisdiction over the low value task order.

Digest

1. Protest asserting that the Department of the Army was required to meet certain information technology requirements through a Small Business Innovation and Research phase III award to the protester is dismissed where the protest fails to establish that the task order requirements constitute technology developed under the protester's prior SBIR awards.
2. Protest challenging the Department of the Army's issuance of a task order under the Army's Computer Hardware Enterprise Software and Solutions program is dismissed where the protester does not hold a CHESS contract, Army regulations provide that the CHESS contract is a mandatory source for the requirements at issue, and the awarded value of the task order is below the threshold for GAO's bid protest jurisdiction.

Social: SBIR firm lacks standing to challenge Army's $43,342 DocuSign purchase through mandatory CHESS program without demonstrating connection to prior research.