Signet Technologies, Inc. v. United States, 21-1047

Background

SSA issued an RFQ to establish a single-award Blanket Purchase Agreement (BPA) for standardized physical security systems and related services at ~1,500 SSA locations nationwide. Quotes required Volume I (non-price) and Volume II (price); CTAs (Contractor Teaming Arrangements) were permitted and a completed CTA document was mandatory if proposed.
SigNet (doing business as Convergint) and Securityhunter both submitted quotes; SSA evaluated non-price factors (Corporate Experience, Past Performance, Technical Approach) as significantly more important than price and intended to award on initial quotes.
Securityhunter won the BPA; SigNet protested to GAO and then withdrew that GAO protest. SigNet later filed suit in the Court of Federal Claims challenging the award as arbitrary, capricious, and contrary to the RFQ.
SigNet alleged Securityhunter’s CTA was incomplete (failing to address multiple model-CTA elements) and raised additional evaluation/fairness complaints; Securityhunter asserted SigNet used GAO-protected material improperly and moved to strike/dismiss.
The Court declined to preemptively resolve the GAO-protective-order dispute (denied motion to strike/dismiss on that basis), found SigNet had standing (agency had deemed its quote compliant), and addressed merits under the APA arbitrary-and-capricious standard.
On the merits the Court concluded Securityhunter’s CTA adequately addressed CTA-model elements, SSA’s price analysis and evaluation were reasonable, and SigNet failed to show the award lacked a rational basis; the Court denied SigNet relief and entered judgment for the United States and Securityhunter.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
1) Were Securityhunter’s CTA documents incomplete such that Securityhunter should be disqualified?	Securityhunter’s CTA omitted required model-CTA elements (team activities, ordering procedures, responsibilities, pricing, delivery, liabilities).	RFQ did not require verbatim mirroring of model CTA; Securityhunter’s CTA sufficiently identified roles and responsibilities (ETC’s narrow role, delivery responsibility, ability to subcontract/hire).	Held: CTA was adequate; SSA reasonably accepted Securityhunter’s CTA and did not act arbitrarily.
2) Did SSA’s evaluation (technical, past performance, price analysis) violate the RFQ or lack a rational basis?	SSA skewed price analysis and evaluation in favor of Securityhunter; evaluation was inconsistent/unfair.	SSA performed appropriate, reasonable evaluations and price analysis consistent with RFQ; record supports rational basis.	Held: Evaluation and price analysis were reasonable and entitled to deference; no arbitrary-and-capricious action.
3) Should SigNet’s complaint be struck or dismissed for alleged misuse of GAO-protected materials?	(N/A—SigNet relied on materials from GAO proceedings in its complaint.)	Securityhunter urged striking complaint and dismissal for violating GAO protective order (fruit-of-the-poisonous-tree argument).	Held: Denied motion to strike/dismiss; court declined to rule on GAO-order violation while GAO review pending and declined to apply RCFC 12(f) without GAO determination.
4) Does SigNet have standing / is the Court deprived of jurisdiction because SigNet allegedly failed to comply with RFQ requirements?	(Implicit) SigNet argued it is an interested party and eligible to protest.	Securityhunter contended SigNet failed material RFQ requirements and thus lacked standing.	Held: Court accepted agency concession that SigNet’s quote was timely and compliant; SigNet has standing and the Court has jurisdiction.

Key Cases Cited

Lujan v. Defenders of Wildlife, 504 U.S. 555 (U.S. 1992) (standing burden and Article III principles)
Impresa Construzioni Geom. Domenico Garufi v. United States, 238 F.3d 1324 (Fed. Cir. 2001) (tests for arbitrary-and-capricious review in procurement)
E.W. Bliss Co. v. United States, 77 F.3d 445 (Fed. Cir. 1996) (proposal must conform to material solicitation terms)
Centech Grp., Inc. v. United States, 554 F.3d 1029 (Fed. Cir. 2009) (acceptability requires offer to provide exact thing called for)
Digitalis Educ. Sols., Inc. v. United States, 664 F.3d 1380 (Fed. Cir. 2012) (interested party test and standing in bid protests)
Myers Investigative & Security Servs. v. United States, 275 F.3d 1366 (Fed. Cir. 2002) (definition of interested party under CICA)
Motor Vehicle Mfrs. Ass'n v. State Farm Mut. Auto. Ins. Co., 463 U.S. 29 (U.S. 1983) (agency must consider relevant factors; standard for arbitrary and capricious)
Citizens to Preserve Overton Park, Inc. v. Volpe, 401 U.S. 402 (U.S. 1971) (presumption of regularity and deference to agency decision)
Bowman Transp., Inc. v. Arkansas-Best Freight Sys., Inc., 419 U.S. 281 (U.S. 1974) (reviewer may uphold agency decision if path reasonably discernible)
Dell Fed. Sys., L.P. v. United States, 906 F.3d 982 (Fed. Cir. 2018) (success on the merits as element for permanent injunction)