Full Opinion

In the United States Court of Federal Claims TRAX INTERNATIONAL CORP., Plaintiff, v. No. 26-796 THE UNITED STATES, (Filed: September 22, 2026) 1 Filed under seal: September 3, Defendant, 2026 and Reissued: September 22, 2026 SOUTHWEST RANGE SERVICES, LLC, Defendant-Intervenor. Daniel Graham, McDermott Will & Schulte LLP, Washington, D.C., for Plaintiff. Daniel Hoffman, Civil Division, U.S. Department of Justice, Washington, D.C., for Defendant. Craig Alan Holman, Arnold & Porter Kaye Scholer LLP, Washington, D.C., for Defendant- Intervenor. OPINION AND ORDER LERNER, Judge. I. Introduction Plaintiff TRAX International Corp. (“TRAX”) brings this post-award bid-protest suit challenging a contract award by the U.S. Army (“Army” or “Agency”) for Mission Support Services on a military base in New Mexico. See generally Compl., ECF No. 1. The Parties’ Cross-Motions for Judgment on the Administrative Record (“AR”) are now ripe for decision. Pl.’s Mot. for J. on Admin. R. (“Pl.’s MJAR”), ECF No. 36; Def.’s Cross-Mot. for J. on Admin. R. (“Def.’s MJAR”), ECF No. 40; Def.-Intervenor’s Cross-Mot. for J. on Admin. R. (“SRS’s MJAR”), ECF No. 39. Plaintiff claims the Army’s decision to award a test and evaluation services contract to Southwest Range Services, LLC (“SRS”) was arbitrary, capricious, an abuse of discretion, and contrary to law. Compl. at 1. TRAX seeks to enjoin performance of the Mission Support Services (“MSS”) contract awarded to SRS. Plaintiff asks the Court for permanent injunctive relief on the grounds that 1 This Opinion was filed under seal on September 3, 2026. ECF No. 70. The parties jointly proposed redactions. ECF No. 75. Accordingly, the Court reissues this Opinion with the agreed upon redactions, which are noted with bracketed asterisks ([***]). 1 errors were committed during the procurement process which prevented TRAX from being awarded the contract. Specifically, TRAX argues “[b]ut for the unreasonable and unsupported Factor 1 findings, and the false equivalency assigned to the offerors under Factor 2, there is a substantial chance that the Army would conclude that SRS’s proposal is not worth SRS’s $29.4 million cost premium.” Pl.’s MJAR at 2. TRAX also claims, because SRS did not possess an adequate accounting system, it should have been precluded from winning the contract. Id. at 7–11. Finally, TRAX alleges the Army’s investigation into SRS’s organizational conflict of interest (“OCI”) was incomplete and, therefore, the decision made based on this investigation was arbitrary and capricious. Id. at 26–28. TRAX also maintains the Army’s technical evaluation of Plaintiff’s proposal contained multiple Artificial Intelligence (“AI”) “hallucinations” which gave the false impression that SRS’s proposal was technically superior to TRAX’s. Compl. ¶¶ 62–67. TRAX moved to complete the AR with three proposal evaluations generated by AI corresponding to each of the three offerors in this procurement. Mot. to Complete the Admin. R. (“Mot. to Complete”), ECF No. 28. Briefing on TRAX’s Motion to Complete concluded on July 9, 2026. The Court granted Plaintiff’s Motion as to all three AI-generated documents in a short Order on July 10, 2026, noting that further explanation would follow; that explanation is included below. See infra Part III. II. Background and Procedural History A. Solicitation and Evaluation On May 22, 2025, the Army issued a Solicitation and Request for Proposals under Solicitation No. W51EW7-25-R-A003 (“RFP”). Tab 94 at AR 1442. The RFP sought proposals for support services at the White Sands Missile Range (“WSMR”), an open-air munitions test range, for “experimentation, test, research, assessment, development, and training in support of National Security.” Id. at AR 1443. The award was for a single cost-plus-fixed-fee contract with a 3-month phase-in period, 9-month base period, four 12-month option periods, and a 6-month option to extend services. Id. at 1443–52. The Army evaluated proposals on four factors: (1) Mission Capability, (2) Past Performance, (3) Small Business Participation, and (4) Cost/Price. Tab 122 at AR 2142. The factors were listed in descending order of importance (i.e., Factor 1 was the most important and Factor 4 was the least important). Id. Factor 1 (Mission Capability) contained two subfactors: (a) Management and Staffing and (b) Continuity of Operations. Id. Between these subfactors, Management and Staffing was significantly more important than Continuity of Operations. Id. The RFP stated the non-Cost/Price factors, when combined, were significantly more important than Factor 4, Cost/Price. Id. To allow for complete review of the Management and Staffing subfactor, offerors were to provide details including personnel resumes, organizational flow charts describing management and team structure, and explanations on their approaches to decision-making, responsibility division, and problem resolution. Tab 132 at 2405–06. Offerors were also asked to explain their approach to unexpected shifts in staffing requirements. Id. 2 Under the Continuity of Operations subfactor, the RFP required offerors to submit a transition plan that would “minimiz[e] disruption of operations” and allow them to assume the responsibilities of the contract “without disruption or degradation of performance.” Id. at 2406. The RFP also provided that the Army would assess the “recency, relevancy, source and context of the past performance information,” and assign a performance confidence assessment rating based on that evaluation. Tab 122 at AR 2147–48. Three timely proposals were submitted in response to the RFP: TRAX, SRS, and a third bidder, [***], which is not party to this suit. Tab 262 (“Final Source Selection Decision Document (“SSDD”)) at AR 5116. TRAX’s and SRS’s proposals were evaluated by the Army’s Source Selection Evaluation Board (“SSEB”), a team of technically qualified individuals, and were scored as follows: Id. The SSEB presented a summary of the evaluations and their recommendations to the Source Selection Authority (“SSA”). Tab 261 at AR 5055. The SSA found SRS’s proposal to be technically superior to TRAX’s under Mission Capability (Factor 1) and awarded the contract to SRS at a price of $449,372,096. Final SSDD at AR 5141–42. While both offerors received overall ratings of “Outstanding” under Factor 1, the SSA concluded there was a meaningful distinction between the two proposals under this Factor. Id. at 5139. SRS received two significant strengths and four strengths under the Management and Staffing subfactor compared to TRAX’s one significant strength and two strengths. Id. at AR 5139–40. Under the Continuity of Operations subfactor, SRS received three significant strengths while TRAX received two strengths and one weakness. Id. Because of these differences, the SSA concluded that SRS’s proposal was technically superior under Mission Capability. Id. The SSA found “no meaningful distinction” between the two proposals under both the Past Performance and Small Business Participation factors. Id. at AR 5141. While recognizing that TRAX’s total evaluated Cost/Price was approximately 6.5% lower than SRS’s, the SSA found SRS’s technical superiority justified the price premium. Id. at AR 5141–42. The SSA separately reviewed a cost analysis of the three proposals by the Source Selection Authority Council (“SSAC”). Tab 385 at AR 7984. After reviewing the SSAC’s comparative analysis in addition to the SSEB findings, the SSA determined SRS’s proposal provided the best overall value to the government. Tab 387 at AR 7987. On February 9, 2026, TRAX was sent an unsuccessful offeror letter explaining it had not won the contract, along with debriefing slides and redacted versions of the Army’s Source Selection Decision Document. Tab 392 at AR 8066–67. 3 B. GAO Protest and OCI Investigation On February 17, 2026, TRAX filed a post-award bid protest with the Government Accountability Office (“GAO”). See generally Tab 320 (“GAO Protest”); Tabs 431–32 (“GAO Decision”). TRAX alleged the Agency had failed to identify and investigate SRS’s potential organizational conflict of interest. GAO Decision at AR 9053–57. TRAX argued SRS’s joint venture affiliates, including Electronic Warfare Associates (“EWA”) and Sigma Defense (“Sigma”), produce items similar to those tested at WSMR. 2 Id. at AR 9054. TRAX asserted that SRS, if awarded the contract, would be testing systems, products, and technologies produced by those affiliates, rendering it incapable of providing impartial advice to the government. Id. at AR 9053. In response to these allegations, the Agency initiated an investigation into the purported OCI on March 19, 2026. Def.’s MJAR at 32; see generally Tab 396 AR8121–249 (“OCI Investigation”). As part of that investigation, the Agency obtained declarations from Systems Application and Technologies Inc. (“SA-TECH”), the managing member of SRS, and EWA Warrior Services attesting that SRS had not tested or evaluated tools or products produced by Sigma, EWA, or any other EWA Warrior Services affiliate. Def.’s MJAR at 32–35. The declarants also represented that any SRS testing of products manufactured by these entities would fall outside the scope of WSMR’s mission. Id. at 33. Based on this evidence, Army Test and Evaluation Command (“ATEC”) personnel concluded no product made by EWA or Sigma had ever been tested or evaluated at the White Sands Test Center (“WSTC”), and that such testing was unlikely to occur in the future. Id. Accordingly, the Agency determined TRAX’s allegations regarding SRS’s impartiality were unsubstantiated. Id. at 32. In its May 14, 2026, decision denying TRAX’s protest, GAO concluded the Agency’s investigation into the alleged OCI was reasonable given the Agency’s data review and declarations asserting SRS had not and would not test products made by its affiliates. GAO Decision at AR 9057. The GAO decision also addressed TRAX’s objections regarding the Agency’s assessment of Factor 1 (Mission Capability) and Factor 2 (Past Performance). Id. at AR 9057, 9062. GAO determined it did not have jurisdiction to consider TRAX’s allegation that SRS lacks an adequate accounting system because it concerns the contractor’s responsibility, not technical acceptability. Id. at AR 9052–53 n.1. GAO concluded none of TRAX’s allegations under Factor 1 were sufficient to sustain the protest. Id. at AR 9058. Under Factor 2, GAO found only granular differences between the two proposals on Past Performance and concluded the Agency reasonably found those differences inconsequential. Id. at AR 9061. To the extent the Agency improperly credited SRS for contracts performed by other joint ventures and its affiliates, TRAX could not demonstrate a reasonable possibility of prejudice. Id. GAO did not discuss whether any errors in the evaluation were the result of AI hallucinations. See id. at AR 9058. 2 Sigma Defense acquired Electronic Warfare Associates (“EWA”), the immediate parent of EWA Warrior Services, in April 2024. SRS’s MJAR at 3, 36. EWA Warrior Services is a minority member of the SRS Joint Venture. Id. 4 C. Procedural History TRAX filed the instant Complaint on May 29, 2026. See generally Compl. SRS moved to intervene as a Defendant on June 4, 2026. Mot. to Intervene, ECF No. 10. The Government submitted the AR on June 15, 2026, and TRAX filed a Motion to Complete the AR on June 22, 2026, which the Court addresses separately below. TRAX filed its Motion for Judgment on the AR on June 30, 2026. Pl.’s MJAR. Defendant and Defendant-Intervenor cross-moved for judgment on the AR on July 9, 2026. Def.’s MJAR; SRS’s MJAR. Briefing on the parties’ cross-motions concluded on July 23, 2026. Pl.’s Resp. to Def. and SRS’s Cross-Mots. J. on the AR (“Pl.’s Resp.”), ECF No. 47; SRS’s Reply Supp. Cross-Mot. J. on the AR (“SRS’s Reply”), ECF No. 48; Def.’s Reply Supp. Cross- Mot. J. on the AR (“Def.’s Reply”), ECF No. 50. The parties submitted supplemental briefs on July 24, 2026. Pl.’s Suppl. Br., ECF No. 53; Def.’s Suppl. Br., ECF No. 52; SRS’s Suppl. Br., ECF No. 51. The Court held a hearing on the motions on August 19, 2026. Currently pending are the parties’ cross-motions for judgment on the AR. III. Motion to Complete the Administrative Record Before turning to the parties’ MJARs, the Court explains its decision to grant Plaintiff’s Motion to Complete the AR. ECF No. 28. The Court will separately issue an Order to Show Cause requiring the Government to explain the errors and misrepresentations in its briefing on Plaintiff’s Motion to Complete the AR. That matter will not be addressed in this Opinion. A. Legal Standard for Completing the Administrative Record In resolving a motion to complete the AR, courts undertake the narrow task of determining which documents were “actually before the agency” during the evaluation process. See Axiom Res. Mgmt., Inc. v. United States, 564 F.3d 1374, 1380 (Fed. Cir. 2009); Competitive Innovations, LLC v. United States, 175 Fed. Cl. 296, 303 (2025). A motion to complete the AR seeks to add “information that was generated and considered by the agency” during the procurement but omitted from the record. Smith v. United States, 114 Fed. Cl. 691, 695 (2014), aff’d, 611 F. App’x 1000 (Fed. Cir. 2015). Notwithstanding the conjunctive “generated and considered” language in Smith, this standard is commonly applied disjunctively. Contrast Smith, 114 Fed. Cl. at 695, with Competitive Innovations, 175 Fed. Cl. at 303 (“While an administrative record is typically presumed to be complete, the presumption of regularity may be rebutted by ‘clear evidence of material that was generated or considered by the agency but excluded from the record.’” (emphasis added) (citation omitted)), and Poplar Point RBBR, LLC v. United States, 145 Fed. Cl. 489, 494 (2019) (similar). Under either formulation of the standard, TRAX satisfied its burden as to all three AI evaluations. B. Motion to Complete: Procedural History On June 16, 2026, the parties filed a Joint Letter notifying the Court of a dispute regarding the AR. Joint Letter to the Court (“Joint Letter”), ECF No. 27. Plaintiff was ordered to file the Letter as a Motion to Complete the AR, which it did on June 22, 2026. Mot. to Complete. In its Motion, Plaintiff asked the Court to order Defendant to submit documents 5 detailing the Army’s use of FAST TRACK, an AI platform, during the evaluation process of the three proposals: [***] (Offeror A), TRAX (Offeror B), and SRS (Offeror C). Id. at 1. The Government responded to Plaintiff’s Motion to Complete on June 26, 2026, arguing the three AI outputs should not be included in the AR. See generally Def.’s Resp. to Mot. to Complete, ECF No. 32. Defendant stated the only AI output viewed by the SSEB was the report for Offeror A ([***]), and because none of the AI reports were deemed usable, they were never entered into the contract file or utilized in the decision-making process. Id. at 2–3. In support of its position, the Government filed two declarations: the first from [***], SSEB Chairperson for the WSMR Mission Support Services solicitation, and the second from [***], Procurement Analyst with Mission and Installation Contracting Command Headquarters, Theater Support Center. Def.’s Ex. A (“[***] Decl.”), ECF No. 32-1; Def.’s Ex. B (“[***] Decl.”), ECF No. 32- 2. In his declaration, Procurement Analyst [***] explained he was tasked with assessing the capability of FAST TRACK “to determine whether it could be used in future source selections.” [***] Decl. ¶ 4; accord Gov’t Resp. to Mot. to Complete at 2. As part of this assessment, Mr. [***] created AI outputs for all three offerors involved in the WSMR procurement. Mr. [***] subsequently displayed the AI output for [***] on a screen for the SSEB to view. [***] Decl. ¶ 5. The SSEB “did not receive digital or physical copies of [[***] output].” Gov’t Resp. to Mot. to Complete at 2. After viewing the output, the SSEB concluded the document “[was] not useable and could not be used as a reliable tool.” [***] Decl. ¶ 4. On July 7, 2026, the Court granted TRAX’s Motion to Complete as to Offeror A, as it was clear the SSEB had reviewed the [***] AI output. ECF No. 38. The Court could not, on the record then before it, determine whether the TRAX and SRS evaluations were reviewed by anyone involved in the procurement. To resolve that question, the Court ordered Mr. [***] and Mr. [***] to supplement their original declarations by answering the following questions: (1) What was Mr. [***] role with respect to the White Sands Missile Range Mission Support Services (WSMR MSS) procurement (Solicitation W51EW7-25- R-A003)? Did Mr. [***] have any decision-making authority over or decision- making role in this procurement? (2) Did Mr. [***] use FAST TRACK or any other AI tool to generate summaries or evaluations of the proposals for Offerors B and/or C? (3) Other than Mr. [***], did any individual with a decision-making role in this procurement view an AI-generated summary or evaluation of Offeror B’s or Offeror C’s proposal? See Order Granting in Part Mot. to Complete. The supplemental declarations were filed on July 9, 2026. Def.’s Ex. C (“Supp. [***] Decl.”), ECF No. 41-3; Def.’s Ex. D (“Supp. [***] Decl.”), ECF No. 41-4. On July 10, 2026, the Court granted the remainder of Plaintiff’s Motion to Complete and ordered the Government to produce the AI evaluations of TRAX’s and SRS’s proposals and file all three AI evaluations with the Court as part of the AR. The parties were also directed to file supplemental briefs on the relevance and impact of the additional documents on Plaintiff’s Complaint. 6 In his supplemental declaration, Mr. [***] acknowledged for the first time that he had shared the AI summaries with three individuals: [***], [***], and [***]. Supp. [***] Decl. ¶ 2. This belated admission is an issue the Court will address separately in a Show Cause Order. What is relevant for purposes of the Motion to Complete, is that two of the three individuals who received the FAST TRACK evaluations of TRAX’s and SRS’s proposals were SSEB members, [***] and [***], the Contracting Officer (“CO”). Tab 211 at AR 4011 (Source Selection Training Presentation identifying [***] as the Past Performance Chair and [***] as a Past Performance Member of the SSEB); Tab 263 at AR 5300 (Past Performance Evaluation Report signature block identifying [***] as WSMR MSS SSEB Chairperson and [***] as WSMR MSS SSEB Member). C. Discussion: The Three AI-Generated Evaluations Were Necessary to Complete the Administrative Record. The AI evaluations are “relevant to the process” by which the Army made its decision, see Oak Grove Techs., LLC v. United States, 156 Fed. Cl. 594, 600 (2021) (“Oak Grove I”), because they “were generated specifically to reflect the comparative merits of the proposals received in response to the RFP.” Pl.’s Reply in Support of Mot. to Complete at 3. They bear directly on the Army’s evaluation process and on TRAX’s claim that AI-assisted review introduced errors that infected its technical evaluation. Id. at 6. It is likewise clear that the Army generated all three AI outputs during this procurement. The Government contends the AI output concerning [***] was generated only after that evaluation was finalized and thus fell outside the decision-making process. See Gov’t Resp. to Motion to Complete at 2–3. Mr. [***] declaration states that “the output of the AI tool did not cause the SSEB to subsequently amend or change Offeror A’s [([***])] evaluations.” [***] Decl. ¶ 4. But had the SSEB found the AI output useful, it could have revised its evaluation. Indeed, the overlap between the AI evaluation for [***] and the SSEB’s final evaluation suggests that it may have done just that. See Pl.’s Supp. Br. at 4–5. As for the TRAX and SRS evaluations, the Government does not contend, as it did for [***], that these were generated only after the corresponding SSEB evaluations had been finalized. The record therefore reflects that generation and review of the AI evaluations occurred during the agency’s decision-making process. Finally, Agency decision makers considered all three documents during the evaluation process. As to [***], the entire SSEB convened to review the FAST TRACK output for [***] proposal. [***] Decl. ¶ 4. Whether the SSEB ultimately found that output “useable” or “reliable” has no bearing on whether it was considered. See id.; Joint Venture of Comint Sys. Corp. v. United States, 100 Fed. Cl. 159, 168 (2011) (“[A]n agency may not exclude information merely on the grounds that it did not rely upon the excluded information when reaching a final decision when there was evidence that the information was, in fact, reviewed.”); Hager Dev. Grp., LLC v. United States, No. 20-819, 2020 WL 4529817, at *4 (Fed. Cl. Aug. 5, 2020) (ordering inclusion of reports that were only “suggestions” for agency decision makers because they “add meaningful context” to the agency’s decision). As to TRAX and SRS, the Government’s supplemental declarations confirm that, once generated, their evaluations were distributed to three individuals involved in the procurement, including the CO and members of the SSEB. Supp. [***] Decl. ¶ 2; Tab 211 at AR 4011. That 7 distribution is likewise sufficient to establish consideration for purposes of completing the record, regardless of whether the SSEB relied upon or used the outputs further. Because all three documents were relevant to the Army’s decision-making process, and because each was generated and considered by the Agency during the evaluation process, they should have been included in the AR. See Westwind Partners, LLP v. United States, No. 24-1504C, 2025 WL 985640, at *2 (Fed. Cl. Mar. 21, 2025) (explaining that the reviewing court must “have before it neither more nor less information than did the agency when it made its decision” (citation omitted)). Thus, the Court ordered the documents’ inclusion in its July 10, 2026, Order. With the record complete, it became apparent that the SSEB’s evaluation of [***] contained multiple passages nearly identical, sentence for sentence, to the AI-generated evaluation of the proposal. Pl.’s Supp. Br. at 4–5 (comparing AR Tab 261 at 5059 with AR Tab 434 at 9089; AR Tab 261 at 5059 with AR Tab 434 at 9090). TRAX identified this in supplemental briefing and at oral argument to support its position that overreliance on AI tainted the technical-evaluation process. Pl.’s Suppl. Br. at 2. Specifically, TRAX argues “the weakness that the Army erroneously assigned to TRAX, and two of the SRS strengths that TRAX challenges in this protest, have analogs in the AI evaluations.” Id. (citation modified). But any substantive or textual overlap in TRAX’s and SRS’s evaluations is minimal. While the Court cannot entirely rule out the use of AI in assessing the proposals, more is needed to support TRAX’s argument that the SSEB over-relied on AI such that the entire evaluation became arbitrary and capricious. TRAX rests its argument on broad assertions that the AI evaluations and the SSEB evaluations reach similar outcomes on some factors. See Pl.’s Suppl. Br. at 2; see, e.g., SRS’s Suppl. Br. at 5 (explaining that although both the SSEB and the AI output reference SRS’s “[***]” organizational structure, this is unsurprising given SRS’s repeated use of that description in its proposal). But TRAX identifies no actual errors or inaccuracies in the challenged evaluation findings that it can trace to AI. Even if the Court were to find AI was relied upon in some way, TRAX has not demonstrated why that reliance independently undermines the validity of the Army’s findings. As SRS states, “TRAX has not explained what remedy or instruction TRAX seeks from this Court related to the Army’s use of AI.” SRS’s Suppl. Br. at 7. Without more, TRAX’s request that the Court consider “[the] use of AI in determining what, if any, deference the Army’s findings deserve” is unavailing. Pl.’s Suppl. Br. at 4. IV. Legal Standard for Bid Protests A. Bid Protests The U.S. Court of Federal Claims reviews an agency’s contract award under the standards set forth in the Administrative Procedure Act (“APA”). 28 U.S.C. § 1491(b)(1), (4). The Court determines whether the Government “acted without rational basis or contrary to law when evaluating the bids and awarding the contract.” Bannum, Inc. v. United States, 404 F.3d 1346, 1351 (Fed. Cir. 2005). A bid award may be set aside if either “(1) the procurement official’s decision lacked a rational basis; or (2) the procurement procedure involved a violation of regulation or procedure.” Off. Design Grp. v. United States, 951 F.3d 1366, 1371 (Fed. Cir. 2020) (citation omitted). To 8 find a rational basis, the Court must determine “whether the contracting agency provided a coherent and reasonable explanation of its exercise of discretion.” Axiom Res. Mgmt., Inc., 564 F.3d at 1381 (citation omitted). To establish a procedural violation, “the disappointed bidder must show a clear and prejudicial violation of applicable statutes or regulations.” Id. (citation omitted). “De minimis errors in the procurement process do not justify relief.” Off. Design Grp., 951 F.3d at 1374 (citation omitted). “Courts look for a reasoned analysis or explanation for an agency’s decision as a way to determine whether a particular decision is arbitrary, capricious, or an abuse of discretion.” Wheatland Tube Co. v. United States, 161 F.3d 1365, 1369 (Fed. Cir. 1998). But an “explicit explanation is not necessary . . . where the agency’s decisional path is reasonably discernible.” DynCorp Int’l, LLC v. United States, 10 F.4th 1300, 1315 (Fed. Cir. 2021) (quoting Wheatland Tube Co., 161 F.3d at 1369–70). “Generally speaking, an agency must evaluate an offeror’s proposal based on the criteria set out in the solicitation.” Tetra Tech, Inc. v. United States, 137 Fed. Cl. 367, 383 (2017). At the same time, “an agency still enjoys ‘great discretion in determining the scope of an evaluation factor.’” Id. (quoting Forestry Survs. & Data v. United States, 44 Fed. Cl. 493, 499 (1999)). “[W]hen weighing the merits of a proposal under a specific evaluation factor, an agency may consider all matters that offerors would reasonably have believed to be within the scope of the factor.” Id. (citation modified) (quoting Forestry Survs. & Data, 44 Fed. Cl. at 497). In addition to establishing agency error under the APA, a disappointed bidder must demonstrate that it was significantly prejudiced by that error. Bannum, Inc., 404 F.3d at 1351. A bidder is significantly prejudiced if “there was a substantial chance it would have received the contract award but for” the agency’s errors. Id. at 1353 (citation modified). “[T]here is no presumption of prejudice when a protestor demonstrates irrationality in an agency decision.” Sys. Stud. & Simulation, Inc. v. United States, 22 F.4th 994, 998 (Fed. Cir. 2021). Finally, while this Court is not bound by GAO’s ruling in a post-award bid protest, the Court typically “gives due weight and deference to GAO recommendations given the GAO’s long experience and special expertise in bid protest matters.” CMS Cont. Mgmt. Servs. v. Mass. Hous. Fin. Agency, 745 F.3d 1379, 1384 (Fed. Cir. 2014) (citation modified); see, e.g., Concourse Grp., LLC v. United States, 131 Fed. Cl. 481, 488 n.3 (2017). B. Cross-Motions for Judgment on the Administrative Record Bid protests pursuant to 28 U.S.C. § 1491(b) are resolved via motions for judgment on the AR, Rule of the Court of Federal Claims (“RCFC”) 52.1(c), a process “properly understood as intending to provide for an expedited trial on the record.” Bannum, Inc., 404 F.3d at 1356. The process is “designed to provide for trial on a paper record, allowing fact-finding by the trial court.” Id. In deciding cross-MJARs, this Court considers “whether, given all the disputed and undisputed facts, a party has met its burden of proof based on the evidence of record.” XOtech, LLC v. United States, 950 F.3d 1376, 1379–80 (Fed. Cir. 2020) (quoting Palantir USG, Inc. v. United States, 904 F.3d 980, 989 (Fed. Cir. 2018)). V. Discussion 9 A. The Army Did Not Err in Finding SRS Eligible for Award. TRAX claims SRS should have been ineligible for award because it lacks an accounting system that meets the requirements of Section L.7.1 of the RFP. Pl.’s MJAR at 9–11. The Government responds that the accounting-system provision in Section L is not an evaluation criterion upon which the award could be based, rendering this a contract administration claim that falls outside the Court’s jurisdiction. Def.’s MJAR at 31; Def.’s Reply at 4. As explained below, this issue was properly before the Court, and the Army did not act arbitrarily or capriciously in making the award to SRS notwithstanding the absence of its own approved accounting system. 1. The Court Has Jurisdiction to Consider TRAX’s Adequate Accounting Claim. The Tucker Act grants this Court jurisdiction over bid protests brought by “an interested party objecting to a solicitation by a Federal agency for bids or proposals for a proposed contract or to a proposed award or the award of a contract or any alleged violation of statute or regulation in connection with a procurement or a proposed procurement.” 28 U.S.C. § 1491(b)(1). Matters of contract administration and contract performance, however, fall outside that grant and must instead be pursued under the Contract Disputes Act. See Cont’l Serv. Grp., Inc. v. United States, 722 F. App’x 986, 992 (Fed. Cir. 2018); Relyant Glob., LLC v. United States, 146 Fed. Cl. 817, 823 (2020). Whether a claim challenges the award decision itself, as opposed to the Government’s administration of a contract already awarded, requires the court to look past labels to the substance of the relief sought. See Distributed Sols., Inc. v. United States, 539 F.3d 1340, 1344–46 (Fed. Cir. 2008). The Government’s threshold argument cites Relyant for the proposition that TRAX’s accounting-system challenge is a contract administration claim outside this Court’s jurisdiction. Def.’s MJAR at 31. But Relyant turned on the timing of when, during contract performance, an awardee needed to obtain a security clearance as required by the solicitation. 146 Fed. Cl. at 822–24 (finding the protestor’s principal objection was that the Army allowed the awardee to begin mobilization activities before the awardee secured a facility security clearance). TRAX’s claim, by contrast, concerns whether the accounting-system provision was a material requirement of award in the first instance. See Pl.’s Resp. at 2–7. Both the Court of Federal Claims and the Federal Circuit have consistently treated similar requirements as going to the technical acceptability of the awardee’s proposal, not to jurisdiction. See, e.g., Oak Grove Techs., LLC v. United States, 116 F.4th 1364, 1380 (Fed. Cir. 2024) (“Oak Grove II”) (evaluating whether a Section L requirement was material, and therefore whether an offeror’s failure to submit under it rendered the proposal unawardable); Banknote Corp. of Am. v. United States, 56 Fed. Cl. 377, 382–83 (2003) (resolving the materiality of an RFP provision on judgment on the AR), aff’d, 365 F.3d 1345 (Fed. Cir. 2004). TRAX’s central claim is that the Army should never have awarded the contract to SRS, because at the time of submission, SRS’s proposal failed to satisfy what TRAX contends is a material requirement of the RFP. Whether an RFP provision functions as a material eligibility criterion is a question about the propriety of the award decision and so falls within Section 1491(b)(1). See Oak Grove II, 116 F.4th at 1380. 10 2. The Accounting-System Requirement Was Not a Mandatory Minimum or Material Requirement that Could Serve as a Bar to Award. An agency may not award a contract to an offeror whose proposal fails to conform to a material term of the solicitation. Allied Tech. Grp., Inc. v. United States, 649 F.3d 1320, 1329 (Fed. Cir. 2011). A requirement is “material” where it (1) is express in the solicitation and (2) serves a “substantive purpose,” meaning it is important to the agency’s evaluation, binding on the offeror, or has more than a negligible effect on price, quantity, or quality. DigiFlight, Inc. v. United States, 150 Fed. Cl. 650, 657 (2020). A “mandatory minimum” requirement is a type of material requirement, the violation of which leads to outright rejection of a proposal, rather than a mere reduction in score. Id.; ManTech Telecomms. & Info. Sys. Corp. v. United States, 49 Fed. Cl. 57, 67 (2001), aff’d, 30 F. App’x 995 (Fed. Cir. 2002). A mandatory minimum requirement must be clearly identified as such within the solicitation to “put offerors on notice” of the serious consequences of failing to meet the requirement. Isratex, Inc. v. United States, 25 Cl. Ct. 223, 229 (1992). Whether a given RFP provision rises to a mandatory minimum requires interpreting the solicitation as a whole and giving effect to the plain language of every provision. See Banknote, 56 Fed. Cl. at 383. TRAX argues the RFP “clearly identified an adequate accounting system as a mandatory minimum and material requirement for the award,” and that because SRS lacks “any accounting system, let alone one that has been deemed adequate in accordance with the FAR and the RFP,” SRS is ineligible for award. Pl.’s MJAR at 9–11. The record indicates SRS’s accounting system was in the process of being audited by the Defense Contract Audit Agency (“DCAA”). Tab 217 at AR 4139. Pending that determination, the Army determined it could rely on the accounting system of SRS’s joint-venture member, SA-TECH. Tab 195 at AR 3592–93. TRAX counters that SA-TECH’s accounting system is approved for SA-TECH’s use only, and SRS’s consequent lack of an approved system is disqualifying. Pl.’s MJAR at 11. TRAX grounds this argument in Section L.7.1 of the RFP, which requires offerors to “provide evidence to support that it has an adequate accounting system.” Pl.’s MJAR at 8–9 (citing Tab 132 at AR 2411). TRAX reads this requirement in conjunction with a separate provision that states “[f]ailure to provide a proposal in compliance with the instructions specified in this RFP shall render the Offeror’s proposal non-compliant, resulting in the Offeror no longer being eligible or considered for award.” Id. (citing Tab 132 at AR 2401). Together, TRAX argues, these provisions made an adequate accounting system a mandatory minimum and material requirement for contract award. Id. The Government responds that nothing in L.7.1 requires the Army to assess accounting system adequacy prior to award, and Section L merely outlines “information and instructions” governing proposal preparation, while Section M delineates material evaluation criteria. Def.’s Reply at 4–5; see Tab 122 at AR 2142 (identifying Section M.1 as “Basis for Contract Award”); Tab 132 at AR 2400 (identifying Section L.1 as “Information to Offerors and Instructions for Proposal Preparation”). Critically, the Government notes TRAX identifies no Section M provision addressing any accounting-system requirement, let alone one tying a deficient accounting system to disqualification. Def.’s Reply at 4. TRAX relies on DigiFlight for the proposition that an express requirement serving a substantive purpose is material. Pl.’s Resp. at 3 (citing 150 Fed. Cl. at 657). But the provision at issue in DigiFlight was more consequential than the Section L provision at issue here. There, the 11 Section L requirement that offerors justify any profit above a set threshold was repeated in Section M and expressly tied to award eligibility. DigiFlight, 150 Fed. Cl. at 658. The solicitation warned noncompliance with the provision “will result in a determination that Profit is not fair and reasonable and the Offeror would not be eligible for award regardless of their technical score.” Id. Section M further provided that any proposal failing to comply with the instructions in Sections J, K, or L could be removed from consideration without further evaluation. Id. at 653. The Court found the Solicitation “clear and unambiguous” that the profit- rationale provision was material. Id. at 657. Comparable provisions are absent here. Def.’s Reply at 5. The WSMR RFP’s Section M is silent on accounting-system adequacy. And the general provision TRAX invokes—that noncompliance with “the instructions specified in this RFP” renders a proposal ineligible—is far less specific than the relevant DigiFlight language. See Pl.’s MJAR at 8. Unlike a provision singling out one requirement as outcome-determinative, a catch-all compliance clause does not render every section in a Solicitation material. TRAX’s reliance on FreeAlliance.com is also unpersuasive. There, the protestor was excluded from further consideration for failing to comply with a Section L requirement to submit verification of an adequate accounting system. FreeAlliance.com, LLC v. United States, 135 Fed. Cl. 71, 73 (2017). That requirement was an explicit “go/no-go” evaluation criterion applied as a disqualifying, separate screening step to every offeror. Id. at 74. Further, the Agency rejected the protestor’s proposal “[i]n accordance with section M.2.a(2)”—a section M provision. Id. at 76. The Court ultimately held the agency had not abused its discretion because it treated all offerors equally, that is, applied the same accounting-system criterion to every offeror. Id. at 80 (“None of the offerors with noncompliant features in their proposals that FreeAlliance relies on proceeded to phase two evaluation.”). TRAX does not allege disparate treatment here, and, as the Government points out, “there is no evidence that the Army would have excluded TRAX – but not SRS – had both not met the administrative requirements of section L.7.1.” Gov’t Reply at 9 n.7. Because FreeAlliance.com turned on equal treatment, its holding offers TRAX little support. By contrast, Oak Grove II provides a closer parallel to the instant facts. 116 F.4th at 1379. There, the Federal Circuit held that an agency did not act arbitrarily or capriciously in finding a proposal acceptable despite its omission of a sample teaming agreement because the teaming agreement provision was n