L3Harris Technologies Integrated Systems LP (B-422943; B-422943.2)

You should not care.

Category: Technical evaluation, phased evaluation

Date: 23 December 2024

URL: https://www.gao.gov/products/b-422943%2Cb-422943.2

L3Harris protested the Army's award of a contract to Sierra Nevada Corporation (SNC) for the integration of High Accuracy Detection and Exploitation Systems (HADES) in aerial intelligence systems. The contract, valued at $991 million, involved a phased evaluation process. L3Harris contested its technical proposal rating of "unacceptable," the agency’s evaluation of SNC’s eligibility, and alleged procedural errors. GAO found the agency’s actions reasonable and consistent with the solicitation.

Technical deficiencies: L3Harris failed to provide required technical elements (e.g., a functional block diagram, an initial electrical loads analysis) within the specified volume and page limits. GAO held the Army reasonably assessed these deficiencies under explicit solicitation criteria.

Disparate treatment claim: L3Harris alleged SNC’s proposal also lacked required details, but GAO found differences justified based on distinct proposal content.

Eligibility of SNC: L3Harris argued SNC’s corporate conversion rendered it ineligible. GAO ruled the conversion constituted a continuation of the entity, validated by its consistent CAGE code and SAM registration.

Other claims: Procedural issues, including discussions and cost/price evaluations, were dismissed as L3Harris was not an interested party due to its ineligibility for award.

The protest was denied in part and dismissed in part.

Digest

Protest challenging agency’s evaluation of protester’s proposal as technically unacceptable is denied where the record shows that the evaluation was reasonable and consistent with the terms of the solicitation. Protest that agency disparately evaluated proposals is denied where the record shows that the differences in the evaluation arose from differences in the respective proposals. Protest arguing that awardee was ineligible for award because the awardee submitted its proposal under its corporate entity name after it had converted to a limited liability company is denied where the record shows that the awardee effectuated its conversion and name change in accordance with applicable laws and regulations. Protester that was properly evaluated as technically unacceptable and would therefore not be eligible for award is not an interested party to raise other challenges to agency’s evaluation and award decision.