Matter of: KE System Services, Inc.
GAO · Dec 22, 2025
- Jurisdiction
- federal
- Court
- GAO
- Record ID
- matter-of-ke-system-services-inc-2025-12-22
- Observed outcome
- Protest dismissed; formal warning issued to the protester regarding the submission of fabricated legal authorities.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The GAO dismissed the protest for lack of standing as an interested party. While the GAO identified that the pro se protester submitted fabricated legal citations and quotes likely generated by AI, it declined to impose sanctions in this instance, instead issuing a formal warning that future submissions of non-existent authority may result in sanctions.
Fabricated: Case Law | Citation to 'KAES Enters., B-420916.2, 2022 CPD ¶ _' could not be located; the B-number corresponds to an unrelated unpublished decision and no published GAO decision matching the citation exists. || False Quotes: Case Law | Protester attributed direct quotations to GAO decisions that, when located, did not contain the quoted language; GAO could not verify the quoted passages. || Fabricated: Case Law | Multiple B-number or CPD citations provided by the protester could not be located or did not support the legal propositions for which they were cited.
This record documents a Pro Se Litigant filing issue in GAO, with the listed outcome: no adjudicated outcome recorded.
Failure modes and consequences
- Fabricated Case Law
- Fabricated Citations
- False Quotations
- Lack Of Verification
- Pro Se
- Fake Citations
- AI attribution
- Implied
- Recorded tool
- Large-language model (unspecified)
- Known monetary consequence
- Not recorded
- Procedural posture
- Bid protest dismissed by the GAO for lack of interested party status, with an accompanying warning regarding the submission of fabricated legal authorities.
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
The GAO attributed the errors to the use of a large-language model.
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
- Verify each cited authority, quotation, and proposition against the underlying source before filing.
- Confirm that every authority actually supports the proposition for which it is offered.