Raven Investigations & Security Consulting, LLC (B-423447)

You should not care.

Category: Sole source, cancelation

Date: 7 May 2025

URL: https://www.gao.gov/products/b-423447

Raven Investigations & Security Consulting, LLC, protested a sole-source award issued by the Department of Homeland Security’s Immigration and Customs Enforcement to Universal Strategic Advisors LLC for administrative processing support services under RFQ No. 70CDCR25Q00000007. Raven alleged that the awardee used nonpublic information to win the contract, challenged the limited sources justification, and claimed DHS failed to consider Raven’s unsolicited proposal. It also raised ethics allegations under 18 USC §207 against USA’s CEO and DHS personnel.

The case became moot when DHS voluntarily terminated the order and, by extension, canceled the RFQ—prompting GAO to dismiss the protest as academic. While Raven argued the termination was pretextual and designed to avoid review, GAO noted that regardless of motive, cancelation rendered the dispute legally moot.

Notable in this case was GAO’s warning over Raven’s use of fictitious legal citations. In its responses to DHS and the awardee’s dismissal motions, Raven’s representative—who is not an attorney—relied on generative AI tools that fabricated legal citations and quotations. GAO flagged this as a misuse of its bid protest process and cautioned that future violations may result in sanctions, even for pro se litigants.

The protest was dismissed as academic after the agency terminated the underlying order. No findings were made on the merits.

Digest

1. Protest of sole-source order is dismissed as academic where the agency has terminated the order for the government’s convenience.
2. Protester is advised that citation irregularities may result in the imposition of sanctions.