A catch-22 is an impossible, no-win situation where you are caught between two conflicting requirements, and complying with one makes it impossible to comply with the other. When a bid protest turns on whether an agency’s instructions were clear or whether a contractor was put in a catch-22, the solicitation is often the best place to look for the answer. However, a recent GAO decision illustrates that not every difficult or unfavorable outcome constitutes a catch-22, and that sometimes the answer to a contractor’s problems is right in front of them.
In The JAAW Group, LLC, B-42433.22 (Comp. Gen. July 31, 2026), GAO dismissed The JAAW Group’s (“JAAW”) protest challenging the Department of the Army’s rejection of its joint venture Paralaxx LLC’s proposal due to alleged inconsistencies in file naming convention instructions between the solicitation and the proposal submission portal.
Under the solicitation, the Army planned to award up to 70 indefinite-delivery, indefinite-quantity (IDIQ) contracts to “establish a marketplace for the acquisition of professional services (MAPS)” to provide “uncommon knowledge-based professional services and support [for] the Army enterprise infrastructure and infostructure goals with information technology services worldwide.”
The solicitation explicitly required offerors to submit proposals in the Digital Market Portal and use specific file naming conventions to be accepted as a full and complete package. Before the solicitation was issued, the Army conducted an industry day virtual listening session and gave a presentation on the process for registering an account on the Digital Market Portal and submitting proposals. Specifically, the presentation advised offerors to “ensure all files are named in accordance with the RFP to be valid package submissions.” The presentation slides were thereafter posted on SAM.gov for offerors to refer back to.
When it came time to submit its proposal, JAAW claimed that the Digital Market Portal set out a different file naming convention than the Solicitation. JAAW argued that Paralaxx was faced with a catch-22: follow the instructions in the solicitation and have its proposal rejected by the portal or submit a proposal in the portal that did not conform to the requirements in the solicitation.
However, GAO determined that this was not the case and that “the record reflects the rejection of the protester’s proposal submission attempts was not due to any inconsistency between the Portal’s and the RFP’s file naming convention instructions but was due to JAAW’s own failure to follow those instructions.” Unfortunately for JAAW, it had included screenshots of its attempts to submit Paralaxx’s proposal into the Digital Market Portal which showed that the file names it had used did not comply with the solicitation requirements.
So, what was wrong with Paralaxx’s naming conventions? Let’s look at an example. The solicitation required the cover letter volume to be named “xxxxCOVERDDMMMYYYY” where the “xxxx” was intended to be replaced with the offeror’s name and the “DDMMMYYYY” was intended to be replaced with the offer date in day, month, year format. To comply with this required naming convention, Paralaxx would have needed to name its cover letter volume file “PARALAXXCOVER22JUN2026” or “PARALAXXLLCCOVER22JUN2026.” Instead, Paralaxx made four different failed attempts to submit the cover letter volume file.
On its first attempt, Paralaxx used the file name “PARALAXXLLCVOLUME122JUN2026” which omitted the word “COVER” and replaced it with “VOLUME1.”
For its second attempt, Paralaxx used the file name “COVERLETTERVOLUME122JUNE2026” which omitted its name and incorrectly added “LETTERVOLUME1.”
On its third attempt, Paralaxx used the file name “PARALLAXMULTICOVER122JUN2026” which improperly added “MULTI” and “1.” Additionally, Paralaxx improperly spelled its name.
For its final attempt, Paralaxx used the file name “XXXXPARALLAXMULTICOVER22JUN2026” which improperly added “MULTI” and left in the “XXXX” placeholder text. Paralaxx again spelled its name incorrectly.
Based on the record, GAO found that JAAW’s claim that the naming conventions in the Solicitation and Digital Market Portal were inconsistent was factually inaccurate. Specifically, GAO noted that “the portal submission screenshots submitted by the protester, itself, reveal the reason JAAW was unable to submit a proposal is because the protester repeatedly, and in a variety of ways, failed to comply with the RFP’s and Portal’s consistent file naming convention requirements.”
So, then what was the legal basis for GAO dismissing (rather than denying) JAAW’s protest? Well, a protest filed with GAO is required to “set forth a detailed statement of the legal and factual grounds of [the] protest including copies of relevant documents.” 4 C.F.R. § 21.1(c)(4). Further, protest submissions are required to be “concise and logically arranged, and should clearly state legally sufficient grounds of [the] protest.” 4 C.F.R. § 21.1(f). GAO may dismiss a protest for failure to comply with such requirements, and that is what happened in this case. See 4 C.F.R. § 21.1(i).
The screenshots JAAW submitted with its protest contradicted JAAW’s argument that Paralaxx was unable to submit its proposal due to inconsistencies between the solicitation and portal. Accordingly, GAO found that “JAAW’s protest rests on a foundation of unsupported assertions [and] it fails to meet our threshold requirement that a protestor provide a detailed statement of the legal and factual grounds of [the] protest.”
Unfortunately for JAAW, GAO also required that it correct two of its citations – one that could not be found and another improperly applied to an argument. Although GAO did not exercise its right to impose sanctions, it cautioned against the use of artificial intelligence in bid protests, noting that “the use of AI tools to draft or assist in drafting legal filings can result in the citation of non-existent decisions, such that reliance on those tools without review for accuracy wastes the time of all parties and of GAO.” However, GAO’s sentiment regarding the use of artificial intelligence is certainly not new as we have previously blogged about this topic here.
There are multiple important takeaways from this case. The first is that reading the instructions is sometimes the best way to avoid a simple mistake that may ultimately prevent you from receiving an award or prevailing in a protest. The second is that artificial intelligence is not a tool to be exclusively relied on when drafting a bid protest or other legal document. If you find yourself in a catch-22 or plan to file a bid protest with GAO, you can always reach out to federal government contract attorneys like ourselves.
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