GAO Denies Kratos Protest: A Cautionary Glimpse into Evaluation Risk and Proposal Clarity

In a decision issued on June 12, 2025, the Government Accountability Office (GAO) denied the protest filed by Kratos Defense & Rocket Support Services, Inc., challenging the Department of the Navy’s task order award to Salient CRGT, Inc. for support services to the Royal Saudi Naval Forces. The task order, competed under the Navy’s Seaport-NxG vehicle, involved a complex blend of training, logistics, and curriculum development work in the Kingdom of Saudi Arabia.

The protest raised several issues, including alleged misevaluation of technical proposals, unequal treatment, and an unreasonable best value tradeoff. Ultimately, GAO found the Navy’s evaluation to be both reasonable and consistent with the solicitation and applicable law. But beyond the denial itself, the decision offers a window into the types of arguments that may — or may not — gain traction in the protest process.

Kratos took issue with the assessment of two weaknesses in its proposal under the performance approach factor. One involved the Navy’s concern that Kratos’s managers might engage directly with the RSNF without sufficient coordination through the Navy’s oversight authority, NETSAFA. GAO upheld the agency’s interpretation, pointing to the language in Kratos’s submission that left room for uncertainty. While Kratos argued this was a misreading, GAO noted that vendors bear the responsibility to clearly convey their intended approach.

The second weakness involved Kratos’s recommendation to use its proprietary software in support of curriculum development. The Navy saw this as potentially creating vendor lock-in — a reliance on a single contractor’s system that could complicate future transitions or recompetitions. Although Kratos contended that its proprietary tool was not being mandated and was merely part of a broader suggestion, GAO found the evaluators’ caution reasonable given the context and the way the proposal was written.

Salient, on the other hand, received an “outstanding” rating under the performance approach factor, with multiple assessed strengths and no weaknesses. Kratos argued that several of these strengths mirrored features also present in its own submission — particularly in areas like communication strategies and software tools — and thus should have warranted equal recognition. GAO disagreed, concluding that the distinctions were not just semantic. The evaluators found Salient’s approach to be more proactive, particularly in how it proposed to keep Navy personnel informed, and that its reliance on commercially available software avoided the concerns raised in Kratos’s proposal.

The protest also raised questions about the treatment of past performance, especially with regard to Salient’s affiliates. The Navy had credited Salient with past performance from both its parent and subsidiary — including work performed under the incumbent contract — on the basis that those entities would be directly involved in performing the new task order. GAO accepted this rationale, noting that the shared personnel, facilities, and operational structure described in Salient’s proposal supported the agency’s conclusion.

Finally, Kratos challenged the best value tradeoff, questioning whether an 8% price premium was justified. GAO found the Navy’s source selection decision to be adequately documented and reasonable. The decision noted Salient’s clear technical advantage, especially under the most heavily weighted factor, and the mission-critical nature of the work supporting U.S.–Saudi naval cooperation.

Taken together, the decision may not chart a new course in GAO jurisprudence, but it does reinforce certain themes. In particular, it suggests that agencies have broad discretion when their evaluation is rooted in the solicitation and supported by the record — and that clarity and context in proposal writing remain crucial.

For contractors, the Kratos decision might serve less as a directive than a reflective prompt. It invites a closer look at how technical approaches are described, how proprietary tools are framed, and how past performance is linked to proposed resources. While a protest may seem appropriate where strengths are unrecognized or weaknesses feel overstated, this case underscores that disagreement with an agency’s evaluation is often not enough.

Disclaimer: This blog post is a general summary for informational purposes only. It is not legal advice. Readers are encouraged to consult with counsel before relying on any information presented. All credit to the authors and the U.S. Government Accountability Office for the original decision.