JDSAT, Inc. (B-423868)

You should not care

Category: Scope challenge, Rule of Two, task order jurisdiction

Date: 12 January 2026

URL: https://www.gao.gov/products/b-423868

JDSAT protested a Navy solicitation for professional services issued under the BUMED Operations, Plans & Readiness multiple-award contract. The company argued the requirement was outside the scope of the underlying vehicle and should instead have been set aside for small businesses under the Rule of Two.

GAO denied the scope challenge. It found the BUMED contract was drafted broadly enough to encompass the disputed work, including analytics, process improvement, technology support, and even newer AI/ML-related tasks that vendors could reasonably have anticipated under the vehicle. JDSAT’s more detailed later arguments were also treated as an impermissible piecemeal presentation of protest grounds.

GAO dismissed the Rule of Two allegation for lack of jurisdiction because the anticipated task order value fell below the threshold for GAO review of that type of task-order protest. The protest is denied in part and dismissed in part.

Digest

1. Protest asserting that task order solicitation for professional services exceeds the scope of its underlying multiple award contract is denied where the record shows that the requirement was reasonably encompassed within the contract's scope of work.
2. Protest asserting that agency failed to undertake a "Rule of Two" analysis prior to issuing a solicitation on an unrestricted basis is dismissed for lack of jurisdiction where the anticipated value of the task order is below the threshold for GAO jurisdiction.