GAO B-424244 (Business Integra): AI citations in a bid protest
A dated timeline from the decision, the exact words on AI, and what GAO did and did not do about it. Decision read on .
The outcome
Protest denied, May 12, 2026. No sanction; a warning about future filings.Business Integra Technology Solutions, Inc. protested a Navy award to HII Mission Technologies Corporation under RFP No. 25R5032. GAO denied the protest on the merits and, separately, found the protest's case citations inaccurate. It chose not to sanction and warned that future filings with non-existent citations may be.
Timeline from the decision
Dates are the ones the decision states. Each entry gives the page of the decision.
- Navy issues the solicitation
The Department of the Navy issues request for proposals No. 25R5032 for security, information technology and other general services at six locations in the United States, a cost-plus-fixed-fee contract with a 12-month base period and four 12-month option periods.
Decision B-424244, page 1 - Proposals due
The Navy receives four proposals by the closing date, including one from Business Integra Technology Solutions, Inc. and one from HII Mission Technologies Corporation. The decision gives no dates for the award, the debriefing or the protest filing.
Decision B-424244, page 3 - GAO denies the protest
GAO denies the protest: the Navy reasonably rated the protester's proposal marginal, which made it ineligible for award, so GAO dismisses the remaining allegations because the protester is not an interested party to raise them.
Decision B-424244, page 4 - GAO addresses inaccurate citations
In a separate section the decision lists case citations in the protest that do not match any GAO decision, says they "bear the hallmarks of the use of a large-language model or other artificial intelligence (AI) tools without adequate verification," and chooses not to impose sanctions while warning that future filings with non-existent citations may bring them.
Decision B-424244, page 16
What GAO wrote about the citations
“the protester's erroneous citations bear the hallmarks of the use of a large-language model or other artificial intelligence (AI) tools without adequate verification that the generated results were accurate.” (page 16)
The protest cited decisions that GAO could not match. Two examples from the decision:
- Apogee Research, LLC, B-414829.10: GAO has not issued a decision with that B-number and party name; a published decision, Apogee Engineering, LLC, B-414829.2 (Feb. 21, 2019), does not discuss unstated evaluation criteria.
- Synergy Companies, LLC, B-419479 (2022): GAO has not issued a decision with that name, B-number and date; the B-number belongs to an unpublished decision of January 21, 2021 that dismissed a protest as academic.
GAO asked the protester to address the basis for the inaccurate citations. The protester answered that they were “several clerical errors” and supplied corrected citations. GAO wrote that the response “fails to address the basis for the inaccurate case citations, as we expressly requested.”
“Here, we deny the protest on the merits and do not exercise our right to impose sanctions for the submission of non-existent citations.” “The protester, however, is advised that any future submission of filings to our Office with citations to non-existent authority may, after review of the totality of the circumstances, result in the imposition of sanctions.” (page 17)
The dollar figures in the decision are not a penalty
| Figure | What it measures |
|---|---|
| $166,226,487 | Evaluated cost of the Business Integra proposal (decision table, page 3). |
| $185,344,992 | Evaluated cost of the HII proposal (decision table, page 3). |
| $19 million | The difference the source selection authority weighed against what it called a "deeply flawed proposal" (page 3). |
The decision imposes no monetary amount on anyone.
Read next
For how forums respond when filings carry citations that do not exist, see what happens if AI hallucinates in a court filing on aivortex.io. A court order from October 2026 that refers counsel to a bar: Lisandrillo v. Palozzi. The older anchor case: Mata v. Avianca.
Before you rely on this
This page summarizes one agency decision; it is not legal advice. Read the decision itself before citing it. It is a GAO bid protest decision, not a court ruling.
Primary sources (read October 22, 2026)
Questions this page answers
- What did GAO decide in B-424244, Business Integra Technology Solutions?
- On May 12, 2026 GAO denied the protest of a Department of the Navy contract award to HII Mission Technologies Corporation. It found the Navy reasonably rated the protester's proposal marginal under the security and general services factor, which made it ineligible, and dismissed the remaining allegations because the protester was not an interested party to raise them.
- What did GAO say about AI in B-424244?
- In a section titled Inaccurate Citations, GAO listed citations in the protest that did not match GAO decisions and wrote: "the protester's erroneous citations bear the hallmarks of the use of a large-language model or other artificial intelligence (AI) tools without adequate verification that the generated results were accurate." It added that close and careful fact-checking and citation-checking are absolute necessities when using AI.
- Did GAO sanction the protester in B-424244?
- No. GAO wrote: "Here, we deny the protest on the merits and do not exercise our right to impose sanctions for the submission of non-existent citations." It did warn that "any future submission of filings to our Office with citations to non-existent authority may, after review of the totality of the circumstances, result in the imposition of sanctions."
- Is $166 million in B-424244 a penalty?
- No. $166,226,487 is the evaluated cost of the protester's proposal, in the decision's evaluation table; HII's evaluated cost was $185,344,992. Neither number measures a sanction. The decision imposes no monetary amount.
- Is B-424244 a court decision in the AI Vortex corpus?
- No. GAO is the Government Accountability Office, which decides federal bid protests; this decision is not a record in the corpus of court decisions. This page is sourced from the decision itself.