The protester alleged the Army relied on AI-generated proposal evaluations containing “hallucinations” that inflated the awardee’s technical superiority. The Court of Federal Claims held that although AI tools were used during the evaluation process, the protester failed to identify actual errors traceable to AI or show that reliance on AI independently undermined the Army’s rational basis for the award.
TRAX International Corp. v. United States, No. 26-796 (Fed. Cl. Sept. 22, 2026)
Background – The Army issued an RFP for Mission Support Services at White Sands Missile Range, a munitions testing facility in New Mexico. Three offerors submitted proposals: TRAX (the incumbent), Southwest Range Services (SRS), and a third bidder. Both TRAX and SRS received overall “Outstanding” ratings under Mission Capability, but the Army awarded the contract to SRS at $449.4 million—approximately $29.4 million more than TRAX’s proposal. TRAX protested to GAO, which denied the protest, then filed suit in the Court of Federal Claims.
AI in Proposal Evaluation – During discovery, TRAX learned the Army used an AI platform called FAST TRACK to generate evaluations of all three proposals. The protester argued AI “hallucinations” infected the evaluation process, creating a false impression of SRS’s technical superiority. The Court ordered the government to complete the administrative record with all three AI-generated evaluations. Upon review, the Court found minimal textual overlap between the AI evaluation and the final evaluation of TRAX and SRS. The Court held that while it could not entirely rule out AI use in the evaluations, the protester failed to identify specific errors or inaccuracies traceable to AI.
Accounting System Requirement – TRAX argued SRS was ineligible for award because it lacked an adequate accounting system as required by Section L.7.1 of the RFP. TRAX contended this violated a mandatory minimum requirement. The Court disagreed, finding the accounting system provision appeared in Section L (informational instructions) rather than Section M (evaluation criteria). Unlike mandatory minimums clearly identified in solicitations with outcome-determinative language, this provision served an administrative purpose. The Court held the Contracting Officer acted within her discretion in finding SRS could use its partner’s approved system pending completion of its own audit.
Mission Capability Strengths – TRAX challenged three strengths the Army assigned to SRS under Mission Capability. First, SRS received a significant strength for proposing to use the Project Cost Management System (PCMS), a government-owned but contractor-customized tracking system. TRAX argued this was improper because any offeror could use PCMS. The Court found the strength was awarded not merely for using PCMS, but for SRS’s approach to leveraging its customized workflows and incumbent personnel’s familiarity with the system to ensure continuity. Second, SRS received a significant strength for its streamlined management structure with fewer supervisory layers. TRAX claimed its smaller program management office was more efficient. The Court deferred to the agency’s judgment that SRS’s organizational chart showed more direct reporting lines. Third, SRS received a strength for proposing “visionary tools” like augmented reality capabilities to manage surge staffing requirements. TRAX argued this unstated criterion violated procurement law. The Court held that considering innovative technologies was reasonably related to the RFP’s express requirement to handle unpredictable workload fluctuations.
Past Performance Evaluation – TRAX alleged the Army improperly credited SRS with past performance from three contracts performed by entities that would not contribute to the current contract. The Court found that even assuming error, TRAX could not demonstrate prejudice because SRS likely would have retained its “Substantial Confidence” rating based on its five years of incumbent performance with twenty-four “Exceptional” or “Very Good” ratings.
Organizational Conflict of Interest – TRAX claimed the Army failed to conduct an adequate investigation into SRS’s potential organizational conflict of interest (OCI). TRAX alleged SRS would be testing systems produced by its affiliates, including Electronic Warfare Associates and Sigma Defense. The Army conducted a post-award investigation obtaining declarations from SRS’s corporate officers stating they had not tested affiliate products and that such testing was unlikely given the range’s mission focus on weapons systems rather than intelligence equipment. The Army also reviewed delivery data and consulted with range personnel. The Court held the agency’s investigation was reasonable and focused appropriately on the incumbent contract as the best indicator of future tasks.
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The plaintiff is represented by Daniel Graham of McDermott Will & Schulte LLP. The intervenor, Southwest Range Services, LLC, is represented by Craig Alan Holman of Arnold & Porter Kaye Scholer LLP. The government is represented by Daniel Hoffman of the U.S. Department of Justice, Civil Division.