Raytheon Co. v. United States, 105 Fed. Cl. 351

Contracting officer’s final decision was barred by the statute of limitations where issued more than six years after the Government’s claim accrued in 1999.
Defendant argues the limitations period begins only after an audit is completed under FAR 48 C.F.R. § 31.201-2.1.
Court previously held the limitations period starts when information equating to knowledge of a potential claim becomes available to the Government.
Defendant sought reconsideration arguing manifest error and citing Holland v. United States (2007).
2003 material and a 2004 agreement were introduced; the court did not decide their significance, focusing instead on what information was available in 1999.
Court noted the 2003–2004 audit and agreement were completed within the applicable statute of limitations.

Issue	Plaintiff's Argument	Defendant's Argument	Held
When does the statute begin to run?	Raytheon argues information equating to knowledge existed in 1999.	Raytheon contends only audit completion triggers accrual.	Statute begins when knowledge of a potential claim becomes available.
Should reconsideration be granted for manifest errors?	Raytheon seeks relief for alleged errors in the opinion.	Reconsideration requires extraordinary circumstances and new elements.	Reconsideration denied; no intervening change or manifest injustice.
Do later 2003 materials affect the 1999 accrual analysis?	Not directly addressed; potential relevance acknowledged.	New evidence in 2003 could be relevant but did not prove earlier accrual was improper.	Court did not consider 2003 material as controlling; focus remained on 1999 information.

Raytheon Co. v. United States, 104 Fed.Cl. 327 (2012) (statute barred when decision issued more than six years after accrual)
Fru‑Con Constr. Corp. v. United States, 44 Fed.Cl. 298 (1999) (extraordinary-circumstances standard for reconsideration)
Holland v. United States, 75 Fed.Cl. 492 (2007) (manifest error or mistake of fact standard for reconsideration)