CVTEK, LLC (B-423943; B-423943.2)
GAO · Feb 12, 2026
- Jurisdiction
- federal
- Court
- GAO
- Record ID
- cvtek-llc-b-423943-b-4239432-2026-02-12
- Observed outcome
- The protest was denied on the merits, and the protester was issued a formal warning regarding the submission of non-existent legal authority.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The GAO issued a formal warning to the protester after counsel admitted that AI-generated citations in a supplemental protest were fabricated or misrepresented. The GAO emphasized that attorneys must manually verify all AI-generated legal authority and warned that future submissions of non-existent citations may result in sanctions.
Fabricated: Case Law | Supplemental protest included citations to decisions that could not be located or matched to the provided B-numbers/CPD citations; GAO was unable to find the cited authorities. || Misrepresented: Case Law | Some cited decisions that were located did not state the propositions for which the protester relied on them (AI produced citations that mischaracterized authority).
CoCounsel and Westlaw AI output is not self-verifying; pull and read every case before filing.
Failure modes and consequences
- Fabricated: Case Law
- Misrepresented: Case Law
- Fake Citations
- Misrepresented Authority
- Administrative
- Trial
- AI attribution
- Admitted
- Recorded tool
- Westlaw CoCounsel
- Known monetary consequence
- Not recorded
- Procedural posture
- Bid protest before the U.S. Government Accountability Office (GAO) involving a task order award.
Damien Charlotin case archive
Publisher document archive. The recorded document is hosted in the upstream publisher archive.
Open underlying sourceA recorded source link is not a substitute for checking the underlying order, filing, opinion, or disciplinary record.
What this record does—and does not—establish
Counsel confirmed use of Westlaw CoCounsel.
Retained unchanged after audit: the existing summary is source-specific, non-placeholder, and supported by the recorded source link. Read the underlying source before relying on it for legal advice or a filing.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Do not treat a paid legal-research product as a substitute for source verification.
- Verify each cited authority, quotation, and proposition against the underlying source before filing.
- Retain a matter-level record of source checks and corrections.