Island Creek Associates, LLC

B-423301.3 Dec 05, 2025 Jump To FULL REPORT VIEW DECISION RELATED PAGES GAO CONTACTS Highlights Island Creek Associates, LLC, a small business of Saint Leonard, Maryland, challenges the issuance of a task order to StraCon Services Group, LLC, a small business of California, Maryland, pursuant to request for proposals (RFP) No. N0042123R3014, issued by the Department of the Navy, Naval Air Systems Command (NAVAIR) under the Seaport NxG multiple award contract (MAC) seeking program management contractor support services for the Navy's multi-mission helicopter program office. Island Creek alleges that StraCon should be disqualified from award because one of its subcontractors, Precise Systems, Inc., has multiple unmitigatable organizational conflicts of interest (OCIs) as well as a personal conflict of interest. The protest is denied. View Decision DOCUMENT FOR PUBLIC RELEASE The decision issued on the date below was subject to a GAO Protective Order. This version has been approved for public release. Decision Matter of: Island Creek Associates, LLC File: B-423301.3 Date: December 5, 2025 Shane J. McCall, Esq., Nicole D. Pottroff, Esq., John L. Holtz, Esq., Greg P. Weber, Esq., Stephanie L. Ellis, Esq., and Annie E. Birney, Esq., Koprince Law, LLC, for the protester. Craig A. Holman, Esq., Amanda J. Sherwood, Esq., and Dustin Vesey, Esq., Arnold & Porter Kaye Scholer LLP, for StraCon Services Group, LLC, the intervenor. Sharon H. Sachs, Esq., and Beckett H. Lee, Esq., Department of the Navy, for the agency. Michael Willems, Esq., and Evan D. Wesser, Esq., Office of the General Counsel, GAO, participated in the preparation of the decision. DIGEST 1. Request to dismiss post-award protest alleging that the awardee through its subcontractor has unmitigable organizational conflict of interests as untimely is denied where the agency had not conclusively communicated to offerors that the subcontractor was eligible to participate prior to the receipt of proposals. 2. Protest challenging alleged conflicts are denied where the agency's investigation reasonably concluded either that no conflicts existed or that any conflicts were adequately mitigated, and the investigation gave meaningful consideration to all alleged conflicts. DECISION Island Creek Associates, LLC, a small business of Saint Leonard, Maryland, challenges the issuance of a task order to StraCon Services Group, LLC, a small business of California, Maryland, pursuant to request for proposals (RFP) No. N0042123R3014, issued by the Department of the Navy, Naval Air Systems Command (NAVAIR) under the Seaport NxG multiple award contract (MAC) seeking program management contractor support services for the Navy's multi-mission helicopter program office. Island Creek alleges that StraCon should be disqualified from award because one of its subcontractors, Precise Systems, Inc., has multiple unmitigatable organizational conflicts of interest (OCIs) as well as a personal conflict of interest. The protest is denied. BACKGROUND The agency requirements at issue in this procurement are currently being performed through an incumbent contract held by Precise, and for which Island Creek is a subcontractor. Memorandum of Law (MOL) at 6. That contract was awarded in 2018, and as part of their performance of that contract both Precise and Island Creek have access to the agency's Acquisition Management System (AMS) software tool, which contains proprietary information related to various agency acquisitions. Id. Relevant to this protest, Precise developed the AMS tool and maintains it under a separate contract that began in 2017. Id. Of note, the 2018 incumbent contract for the instant requirements included a list of firms that had OCIs, and Precise was not included on the OCI list for the 2018 contract. Id. On February 1, 2024, the agency issued the RFP at issue in this protest as a small business set-aside. Agency Report (AR), Tab 3, RFP at 88, 131.[1] Following 11 amendments, the solicitation set April 25, 2024, as the date for receipt of proposals. Id. at 100. Of note, the RFP also included a list of firms that the Navy had assessed as having OCIs, and Precise was not included on that list. AR, Tab 3.3, OCI List at 215‑217. On April 10, 2024, Island Creek filed a bid protest at the United States Court of Federal Claims (COFC) challenging an unrelated procurement action. In that case, however, Island Creek alleged that the head of the procuring activity (Mr. X), which is the same procuring activity for the procurement at issue in this protest, had a personal conflict of interest because he was married to a program manager at Precise (Ms. Y), and that the agency had impermissibly taken various procurement actions designed to give Precise an advantage due to that conflict. Island Creek Associates, LLC v. United States, 172 Fed. Cl. 729 (2024), at 734 n.2, 735. The COFC protest was subsequently dismissed for lack of standing. Id. at 741.