BNUMBER:  B-265638.2; B-265639.2
DATE:  February 22, 1996
TITLE:  Intercomp Company--Reconsideration

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Matter of:Intercomp Company--Reconsideration

File:     B-265638.2; B-265639.2

Date:     February 22, 1996

Charles D. Ablard, Esq., Jeff H. Eckland, Esq., and William L. 
Roberts, Esq., Faegre & Benson, for the protester.
Susan K. McAuliffe, Esq., and Michael R. Golden, Esq., Office of the 
General Counsel, GAO, participated in the preparation of the decision.

DIGEST

Requests for reconsideration of dismissal of protests based upon 
contract information discovered by protester more than 2 years after 
award are denied where protests essentially concern a matter of 
contract administration and are otherwise untimely.

DECISION

Intercomp Company requests reconsideration of our August 30, 1995, 
dismissal of its protests of the award of contracts to General 
Electrodynamics Corporation under request for proposals (RFP) Nos. 
F41608-92-R-20110 and F41608-92-R-20215, issued by the Department of 
the Air Force for aircraft weighing systems.  

We deny the requests for reconsideration.

We dismissed the protests because of the lengthy period of inaction 
(i.e., 2 years) by the protester during which time the protester 
failed to pursue any information to reveal possible bases of protest.  
The protests were only filed after Intercomp discovered publicly 
available contract information 2 years after award that contract 
performance was assertedly not in accordance with the terms of the 
awardee's proposal.  Intercomp states that it first learned its basis 
of protest when it received the agency's response to a Freedom of 
Information Act (FOIA) request that the firm had filed in pursuit of 
information about an unrelated matter concerning a possible leak of 
the firm's proprietary information by the agency.  Based upon the 
information it received, Intercomp challenged that the agency 
improperly accepted after award the awardee's analog system, which is 
different from the digital system described in the awardee's proposal.

The protester argues that its protest is not a matter of contract 
administration, but rather that the agency's acceptance of a 
nonconforming product constitutes a contract modification outside the 
scope of the original contract which is subject to this office's 
review.  See Ion Track Instruments, Inc., B-238893, July 13, 1990, 
90-2 CPD  para.  31.  Despite Intercomp's characterization of its protests, 
in our view, the protester's challenge that the awardee delivered a 
nonconforming product during contract performance, and that the agency 
has apparently allowed this practice, essentially involves a matter of 
contract administration that we do not review.  See section 21.5(a), 
60 Fed. Reg. 40,737, 40,742 (Aug. 10, 1995) (to be codified at 4 
C.F.R.  sec.  21.5(a); see Louisville Cooler Mfg. Co., B-243546, June 13, 
1991, 91-1 CPD  para.  568.  In any event, as we stated in our prior 
dismissal decision, to the extent Intercomp's challenge reaches the 
propriety of the initial award, the protests are untimely filed.

Intercomp generally reiterates the arguments it made in its initial 
protests regarding timeliness; the request also provides that:

     "Intercomp had no reason to suspect it should affirmatively 
     pursue and investigate the facts forming the basis for this 
     protest at the time of contract award.  This protest is based on 
     the fact that the awardee supplied a different product than the 
     product it had offered in its bid and a different product from 
     what the Air Force had advertised to buy.  That fact only came to 
     light when the Air Force responded to a [FOIA] request made for a 
     reason not related to possible protest."  (Emphasis in original.)

As we stated in our dismissal decision, the policy goal underlying our 
timeliness rules is the expeditious consideration of procurement 
actions without unduly disrupting the government's procurement 
process.  Air Inc.--Recon., B-238220.2, Jan. 29, 1990, 90-1 CPD  para.  129.  
Here, the protester states that it did not pursue any information 
regarding the procurement for more than 19 months after award; during 
this period, Intercomp failed to show any continued interest in the 
procurement.  Although our timeliness rules are not stated in terms of 
a maximum time period available for filing a protest of an award 
action, we cannot permit the timing of the protest process to be 
governed by the protester's own discretionary act of inquiring about 
contract award and performance at a time of its own choosing.  This is 
especially apparent here where a substantial period of time has passed 
since award and contract performance is substantially accomplished, if 
not completed.  To allow the filing of the protests based upon 
information discovered by chance by the protester 2 years after notice 
of award, where no interest in the procurement has been shown during 
that time period, would contravene our longstanding practice of 
allowing only a reasonable limit on the length of time within which 
protests must be filed after notice of award.  See Technology 
Management & Analysis Corp., B-256313.3; B-256313.5, May 9, 1994, 94-1 
CPD  para.  299.  In measuring timeliness and allowing a reasonable time for 
the filing of protests, we require that protesters diligently pursue 
information that may reveal any possible bases of protest.  See Adrian 
Supply Co.--Recon., B-242819.4; B-242819.5, Oct. 9, 1991, 91-2 CPD  para.  
321.

Although the protester here contends that it had no reason to seek 
information at the time of award that would have given rise to its 
current protest bases since the agency's acceptance of different 
equipment than proposed occurred after award, we believe our diligent 
pursuit rule applies to certain discernable points in time after award 
where the protester could have timely shown its continued interest in 
the procurement.  For instance, a request by the protester within a 
reasonable time after award for publicly available information 
concerning the results of first article testing or delivery orders 
under the contract would have resulted in the protester's having at a 
much earlier point in time the information it is now contending gives 
rise to a valid protest.  In light of our interests in minimizing the 
disruption to the procurement process while giving protesters a 
reasonable opportunity to present their cases, the protest process 
cannot be governed by the protester's fortuitous discovery of 
information after it has failed to show interest in the procurement 
for an extended period of time.  

The requests for reconsideration are denied.

Comptroller General
of the United States