TITLE:  4-D Neuroimaging, B-286155.2; B-286155.3, October 10, 2001
BNUMBER:  B-286155.2; B-286155.3
DATE:  October 10, 2001
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Decision

Matter of: 4-D Neuroimaging

File: B-286155.2; B-286155.3

Date: October 10, 2001

Richard B. Oliver, Esq., and William V. Walsh, Esq., McKenna & Cuneo, for
the protester.

S. Gregg Kunzi, Esq., Howard M. Holstein, Esq., and Michael J. Vernick,
Esq., Hogan & Hartson, for CTF Systems, Inc., an intervenor.

Deirdre L. Stallworth, Esq., Frederick M. Quattrone, Esq., and Michael
Trovarelli, Esq., Defense Logistics Agency, for the agency.

Paul E. Jordan, Esq., and John M. Melody, Esq., Office of the General
Counsel, GAO, participated in the preparation of the decision.

DIGEST

1. Technical evaluation identifying various features of awardee's proposal
as advantages was unobjectionable where agency followed solicitation's
evaluation criteria and record establishes that evaluated advantages have a
reasonable basis.

2. Agency's waiver of testing requirement included in solicitation by
mistake did not prejudice protester where cost of the testing is de minimis;
reducing protester's price by cost of the testing would not have affected
the price-technical tradeoff.

3. Agency was not required to conduct discussions regarding what protester
characterizes as perceived weaknesses in its proposal where proposal was
rated acceptable under all factors and "weaknesses" were simply areas where
awardee's higher-rated proposal had relative technical advantages.

4. Price-technical tradeoff was reasonable where source selection official
identified technical distinctions between competing proposals and
specifically determined that higher technically rated proposal represented
best value despite higher cost.

DECISION

4-D Neuroimaging protests the award of a contract to the Canadian Commercial
Corporation (CCC), on behalf of CTF Systems, Inc., under request for
proposals (RFP) No. SP0200-99-R-8031, issued by the Defense Logistics Agency
(DLA) for a magnetoencephalography (MEG) and electroencephalography (EEG)
whole-head scanner system, for use by the National Institute of Mental
Health (NIMH). 4-D principally challenges the agency's determination that
CTF's proposal was technically superior to its own, and that these technical
advantages warranted paying CTF's higher price.

We deny the protest.

BACKGROUND

The MEG/EEG

The whole-head MEG/EEG system is intended for an advanced neuroimaging
research facility at NIMH. The research involves detecting and recording
signals of brain activity during cognitive performance in human subjects.
Two key features are necessary in an instrument designed to detect this
activity: sensitivity (the ability to detect very small signals in a
background of noise) and spatial selectivity (the ability to determine where
in the brain the signals are being generated, and to discriminate among
different spatial patterns of brain activity). Agency Report (AR), Tab 3,
attach. A, para. 1. The two methods of recording this brain activity are the EEG
(electrodes attached to the subject's scalp to read the brain's electrical
signals) and MEG (a large array of superconducting sensor coils, cooled by
liquid helium and arranged in a helmet that fits over the subject's head to
detect the magnetic field generated by the brain's electrical activity). Id.
para. 2.

The sensors--which are either magnetometers or gradiometers [1]--gather
analog signals (flux) from the brain, which are subsequently digitized to
allow the computer to record and analyze the data. Id. para.para. 4, 9. "Primary"
sensors are placed close to the scalp to detect the brain's flux. Because
the primary sensors detect some background magnetic activity (noise), the
MEG also employs "reference" sensors, which are placed far enough away from
the head so as to record only background noise. As part of the noise
cancellation system, the MEG subtracts the reference sensor information from
the primary sensor information to arrive at a more accurate measurement of
the signals. Because the brain's magnetic field is millions of times smaller
than the earth's magnetic field and that of other environmental sources
(e.g., passing vehicles, power lines, and nearby elevators), the MEG is
usually housed in a magnetically shielded room (MSR), and employs other
methods of noise cancellation to obtain more accurate data. Id. para. 2.

The Solicitation

NIMH, through its intramural research program (IRP), plans and administers a
comprehensive, long-term, multidisciplinary brain and behavioral research
program dealing with the causes, diagnosis, treatment, and prevention of
mental disorders, as well as the biological and the psychosocial factors to
determine normal and pathological human behavior. The procurement here was
designed to expand the IRP's neuroimaging research capability to include a
"state of the art electrophysiological brain mapping system . . . capable of
recording over the entire head the magnetic and electrical signals generated
by brain electrical activity." RFP sect. 1.5. The solicited system was to
include an MEG/EEG, turnkey installation, training, data, and extended
warranty, to be furnished on a fixed-price basis. As amended (in response to
an earlier protest by 4-D [2]), the RFP advised offerors that the agency
understood that the MEG/EEG scanner system is specialized commercial
equipment modified (customized) to suit the intended use and physical
configuration of the purchasing institution; that the MEG/EEG scanner
systems offered should be "designed with the most up-to-date technology and
built with the most up-to-date materials"; and that, because the agency
intended to purchase "the most advanced, state-of-the-art MEG/EEG system,"
offerors should "use their best technological abilities in their design of
their offered system," and should review their original proposals for the
purpose of enhancing their designs. RFP, amend. 0006, sect. 6(b), (c).

Proposals were to be evaluated on the basis of price and three technical
factors listed in descending order of importance: technical approach;
maintenance, product and customer support; and past performance. The
technical approach factor included the following equally weighted
subfactors: MEG/EEG system (overall functional performance, hardware design,
and software design) and turnkey/extended installation. RFP at 69-70. These
non-price evaluation factors were considered significantly more important
than price, with price becoming more important as proposals became more
equal technically. Award was to be made to the offeror whose proposal was
most advantageous to the government based on the listed factors.

In response to the amended solicitation, CTF submitted its original
proposal, and 4-D submitted four alternate proposals. The proposals were
evaluated without reliance on the prior evaluations or source selection
documents. Contracting Officer's Statement para. 13. Three of 4-D's proposals
were evaluated as acceptable and one was evaluated as unacceptable and
eliminated from the competitive range. After the agency conducted
discussions with both offerors, the final evaluation results were as
follows:

 Offeror (System)   CCC/CTF      4-D (Magnes  4-D (Magnes   4-D (Magnes
 [3]                (Omega)      WH           WH            WH

                                 ([deleted])  ([deleted]))  ([deleted]))

 1. Technical       HA           A            A             A
 Approach [4]

 (a 1) Functional   HA           A            A             A
 Perf.

 (a 2) Hardware     HA (s)       A (s,w)      A (s,w,w)     A (s,w,w)
 Design

 (a 3) Software     A            A            A             A
 Design

 (b)                A            A            A             A
 Turnkey/extended
 installation

 2. Maint.,         A            A            A             A
 Product, &
 Support

 3. Past            A            A            A             A
 Performance

 Overall Rating     HA           A            A             A

 Price              $2,745,000   $2,173,366   $2,173,366    $2,173,366

In making his award determination, the source selection authority (SSA)
considered that the proposals were rated equal in the areas of software
design, maintenance, product, and customer support, and past performance,
Source Selection Decision (SSD) para.para. 18-24, but found that CTF's proposal was
technically superior, specifically noting the following advantages to its
hardware design as compared to 4-D's: greater number of sensors and
reference channels; use of gradiometer-type sensors; higher front-end
sampling rate; greater dynamic range; ability to recalculate raw data; data
integration; and superior noise cancellation scheme. He concluded that CTF's
proposal was "deservedly the most highly technically rated," SSD para. 6, and
further observed:

[4-D]'s Acceptable proposals are not so technically close to CTF's Highly
Acceptable Omega system that the lower price would increase in importance
relative to technical merit. The overall functional performance of the CTF
Omega system is clearly the most suited for NIMH's research mission. The
Omega system's superior technical proposal warrants the additional cost [26
percent higher] and therefore, I have determined that the award shall be
made to the Canadian Commercial Corporation/CTF.

SSD para. 6. DLA awarded the contract to CCC/CTF on June 20, 2001. After a
debriefing, 4-D filed this protest challenging the technical evaluation, the
conduct of discussions, and the price-technical tradeoff. After reviewing
the agency report, 4-D also challenged CTF's compliance with an RFP
requirement for testing of the MSR. [5]

ANALYSIS

Technical Features

4-D primarily objects to the agency's finding that CTF's proposal offered
several features that were technically superior to 4-D's.

In reviewing a protest against a procuring agency's proposal evaluation, our
role is limited to ensuring that the evaluation was reasonable and
consistent with the terms of the solicitation and applicable statutes and
regulations. National Toxicology Labs., Inc., B-281074.2, Jan. 11, 1999,
99-1 CPD para. 5 at 3. The protester and agency have provided extensive
competing technical arguments in support of their positions. Ultimately,
these submissions and hearing testimony [6] demonstrate that 4-D disagrees
with the agency's judgment, but do not establish that it was unreasonable
for the agency to find that certain features of the CTF system provide
meaningful advantages over the 4-D systems. See Recon-Optical, Inc.,
B-286529, Jan. 18, 2001, 2001 CPD para. 14 at 6. We discuss some of 4-D's
principal arguments below.

In three areas--number of sensors, front-end sampling, and dynamic
range--the protester (through the testimony and written submissions of its
technical expert) does not disagree that the CTF system provided a technical
advantage over 4-D's; rather, 4-D considers any advantage not worth the
price premium paid by the agency, Hearing Transcript (Tr.) at 13-14, 78,
asserting that both offerors' systems are "adequate" to perform as required.
Id. at 78. However, this mere disagreement with the agency's tradeoff
decision (discussed below) does not establish that the evaluation itself was
unreasonable. In this regard, CTF's system offers 275 primary sensors, while
4-D's systems offer only 248, and the TEP chair testified that the
additional sensors proposed by CTF represent an incremental advantage over
4-D's systems. Id. at 11-12. Contrary to the protester's speculation that
CTF's additional sensors would be arrayed in places producing little usable
data, the TEP chair testified that all proposed systems' sensor arrays cover
approximately the same area; CTF simply packs more sensors into that area.
Id. at 9-10, 12. Since the protester's technical expert conceded (prior to
the hearing, where CTF's sensor array was discussed) that "[o]nly an
increased density of the sensors would produce better scientific
results . . . ," there is no basis to question the agency's conclusion that
the extra sensors provide an advantage over 4-D's systems. 4-D Expert's
Supplemental Declaration (Suppl. Decl.), para. 10. Similarly, the hearing
testimony clarified the validity of CTF's more advantageous front-end
sampling rate. The TEP chair testified that CTF's use of digital signal
processing, utilizing a digital flux loop, provided greater flexibility to
the researcher. Tr. at 161-62. The protester's expert conceded that he
understood why the agency considered this a strong point. Id. at 166-67.

As for dynamic range, the agency found that CTF's 32-bit dynamic range
provided an advantage over 4-D's [deleted]bit range because it would more
fully record the brain signal and provided a margin of error or safety to
keep track of the signal during transition states and when transient,
unexpected noise events occur. [7] SSD, para. 16; Tr. at 34, 36, 43, 87-88. As
an example, the TEP chair noted that, in a hospital setting like NIMH,
moving elevators, a passing metal gurney, or a passing oxygen bottle, would
produce a significant magnetic signal that would make a particular portion
of the data bad. Tr. at 74. The protester's expert conceded that data would
be lost due to transient noise events (id. at 102-03), but asserted his
belief that these events were rare and could be handled with fewer bits
given the shielding available in the MSR and the inability of any system to
record signals below the sensors' own noise level (4-D Expert's Suppl.
Decl., para. 13; Tr. at 35-36, 63-64). However, the TEP chair testified in
response that "[i]t's not such a rare event . . . particularly if you're
doing cognitive neuroscience experiments, which last for a long time in
patients which are very difficult to get calmed down and get into the
scanner and into the situation[;] you don't want a transient event to mess
up your experiment." Tr. at 36. Given that the agency is in a better
position to judge the rarity of transient noise events, and that most of the
research to be done with the MEG involves very low frequency signals (Id. at
74-75, 126), which is where most of the noise problems are found (Tr. at
60), we are persuaded that even relatively rare events may interfere with
the agency's research. We conclude that the agency reasonably determined
that the margin of safety offered by CTF's larger dynamic range represented
a distinct advantage over 4-D's systems.

4-D also challenges the agency's conclusion that two elements of CTF's
systems' noise cancellation scheme--its greater number of reference
channels, and its use of third order gradiometers--were superior to 4-D's
system. [8] Regarding reference channels, the agency found that CTF's 29
reference channels, as compared to 4-D's [deleted]channels [9], were
advantageous because they would provide a more accurate determination of the
ambient environmental noise field, which would result in improved noise
cancellation. TEP Chair Suppl. Decl., para. 6; SSD para. 13. At the hearing, CTF's
expert testified that only [deleted]of its 29 reference channels were
necessary for the noise cancellation system, and that the other
[deleted]were for redundancy. Tr. at 120-21. This testimony led 4-D to
assert that this means that the agency's evaluation was flawed because it
should have compared this lower number ([deleted]) to 4-D's
[deleted]channels. This argument is without merit. CTF's expert went on to
testify that its system's [deleted]redundant channels were available for
additional noise cancellation, id. at 121, and 4-D has not asserted or shown
otherwise. Since CTF's additional channels thus are not merely redundant, we
see nothing unreasonable in the agency's basing its comparison on all 29
channels. In any case, even if the agency had based the comparison only on
CTF's [deleted]"necessary" channels, this still was [deleted]more reference
channels than 4-D offered. Moreover, 4-D's president testified that some
unidentified number of 4-D's [deleted]channels were for redundancy, id. at
142, so this difference would be greater. We conclude that the identified
advantage was valid.

With regard to CTF's use of third order gradiometers and the agency's view
that they were superior to 4-D's system (SSD para.para. 13, 17), 4-D asserts that
this terminology is merely a "marketing gimmick" (Suppl. Protest at 3), [10]
and that the combination of the MSR and its own noise cancellation
methodology, similar to CTF's, reaches the noise level of the sensors, and
thus eliminates any advantage. 4-D Expert's Suppl. Decl., para. 15.

We find no basis for disturbing the agency's evaluation conclusion. CTF's
expert testified at length about the operation of the firm's proprietary
system, and explained both its greater flexibility and its ability to lower
the onset of low frequency noise. Tr. at 110-13, 118, 122-25. As explained
by CTF's expert (undisputed by 4-D), lowering the onset of low frequency
noise provides the researcher with a broader range where the noise is
"really clean." Id. at 126. The TEP chair agreed that the ability of the
third order gradiometer to reduce the onset of low frequency noise below
1 hertz (Hz) represented an advantage because the low frequencies are one of
the major interest areas for NIMH research. Id. Even though it was not clear
when the advantage would come into play, the TEP chair testified that CTF's
third order gradiometers, when combined with the additional noise
cancellation features of its MEG, provided a distinct "edge" and
"incremental benefit" over 4-D's. Id. at 133, 151-52, 154.

As evidence of CTF's capability, its expert relied on actual performance
data of its third order gradiometer as compared with a first order
gradiometer--included in CTF's proposal--which showed that CTF's system
effectively lowered the level at which low frequency noise is detected by
the sensors (i.e., the onset of low frequency noise) to .5 Hz. Tr. at
109-10, 125; CTF Proposal, Vol. II, Figure B.11. While the protester at one
point asserted that its system could reduce the onset of low frequency noise
at the .1 Hz level (Tr. at 147), its president later retracted that
assertion, admitting that he was "not sure" of 4-D's specification in this
area (Tr. at 149). Indeed, though 4-D's president represented that 4-D's
specification was contained in its proposal, he was unable to provide a
proposal reference at the hearing, and has not subsequently identified it in
4-D's post-hearing comments. Likewise, 4-D's expert was unable to provide
any definitive information demonstrating that 4-D's system would perform at
the same level as CTF's. For example, while he testified that he knew that a
4-D system had reached the 1 Hz level, he could not recall if it had reached
the .1 Hz level. Tr. at 133. In sum, while 4-D's expert disagreed that there
was any edge to CTF's system, id. at 153-55, he was unable to provide any
persuasive support for his view. We conclude that 4-D has failed to
establish--beyond its unsupported opinion and disagreement with the agency's
conclusion--that its noise cancellation approach performs at the same level
as CTF's third order gradiometers. Accordingly, we have no basis to question
the agency's evaluation conclusion that CTF's system provides a technical
advantage in this area.

Software

4-D challenges the agency's conclusion that the software packages proposed
by 4-D ([deleted]) and CTF ([deleted]) were both acceptable since, it
claims, the [deleted]software package is "demonstrably superior" to CTF's.
[11] Suppl. Protest at 5. Specifically, 4-D's expert opines that 4-D's
[deleted]package "has many more options, exhibits better graphics and is
more compatible with other types of data," and that an unidentified
purchaser of a CTF system purchased the [deleted]software at its own expense
because of its superiority. 4-D Expert's Decl., para. 13; 4-D Expert's Suppl.
Decl., para. 21.

This argument is without merit. The agency explains that the two competing
software packages represented only one among a large complement of packages
proposed by each offeror. Each of the two packages, viewed in isolation, has
both strong and weak points compared to the other, but when each proposal's
total complement of software was evaluated, the TEP judged that both
offerors' software would work equally well to support the offerors' unique
technological approaches. TEP Chair's Suppl. Decl., para. 13. Apart from
generally stating that the [deleted]software is superior to the
[deleted]software, 4-D has provided no specific explanation of how its
software is superior to CTF's software. Nor has it explained how the
remaining packages in its software complement are superior to those in
CTF's. We conclude that 4-D has not established that the evaluation was
unreasonable.

Waiver

4-D asserts that CTF took exception to a material solicitation requirement
concerning performance testing of the MSR. Specifically, CTF's proposal
suggested an alternative based on whether its MEG met the proposed total
system noise specification, and specifically stated that the cost of the
specified testing was not included in its price. DLA essentially concedes
that CTF took exception to the requirement, but explains that the
requirement was included in the RFP by mistake, and that DLA never intended
for the successful offeror to perform the MSR testing.

DLA clearly should have amended the RFP or otherwise apprised offerors that
it had effectively waived this requirement. However, our Office will not
sustain a protest unless the protester demonstrates a reasonable possibility
that it was prejudiced by the agency's actions; that is that, but for the
agency's actions, it would have had a substantial chance of receiving the
award. McDonald-Bradley, B-270126, Feb. 8, 1996, 96-1 CPD para. 54 at 3; see
Statistica, Inc., v. Christopher, 102 F. 3d 1577, 1581 (Fed. Cir. 1996).
Unfair competitive prejudice from a waiver or relaxation of the terms and
conditions of the RFP for one offeror exists only where the protester would
have been able to alter its proposal to its competitive advantage, were it
given a similar opportunity. RGII Tech., Inc.--Recon. and Protest,
B-278352.2, B-278352.3, Apr. 14, 1998, 98-1 CPD para. 130 at 8. Here, there is
no basis for finding that, had 4-D known of the waiver, it would have
changed its proposal to improve its competitive position. DLA states that
the cost of the testing, if required, would be between $5,000 and $11,000,
and a document submitted by 4-D estimates the testing cost as $5,000 plus
travel expenses. Protester's Suppl. Comments at 20; Letter from Testing
Organization at 2. Since the agency already has determined that the
technical advantages of CTF's proposal were worth its $2.74 million, a
premium of 26 percent above 4-D's price, there is no reason to believe that
providing 4-D an opportunity to reduce its price by this de minimis amount
would have affected the award decision.

Discussions

4-D asserts that the agency failed to provide it with meaningful discussions
with regard to three identified weaknesses in its proposed system: recovery
of all raw sensor data; use of mixed [deleted]technology; and failure to
integrate the MEG and EEG data. According to 4-D, had the agency advised it
of these weaknesses, it could have substituted different sensors and
clarified its proposals to eliminate the weaknesses. This argument is
without merit. The points identified by 4-D were not problem areas of its
proposal but, rather, are drawn from the TEP's and SSA's discussion of the
advantages present in the CTF system as compared to the 4-D system. While
agencies' discussions with offerors must be meaningful, agencies are not
required to conduct discussions regarding relative disadvantages of a
proposal that is otherwise acceptable. Avtec, Inc., B-238824, June 22, 1990,
90-1 CPD para. 581 at 4.

Price-Technical Tradeoff

As noted above, much of 4-D's protest concerns its disagreement with the
value of any technical advantages in CTF's proposal. 4-D asserts that the
agency's price-technical tradeoff was flawed because the advantages
identified by the agency were not sufficient to justify paying a 26-percent
price premium.

Source selection officials have broad discretion in determining the manner
and extent to which they will make use of the technical and cost evaluation
results, and their judgments are governed only by the tests of rationality
and consistency with the stated evaluation criteria. Chemical
Demilitarization Assocs., B-277700, Nov. 13, 1997, 98-1 CPD para. 171 at 6.
Where, as here, the RFP allows for a price-technical tradeoff, the selection
official retains discretion to select a higher-priced but also technically
higher-rated submission, if doing so is in the government's best interest
and is consistent with the solicitation's stated evaluation and source
selection scheme. University of Kansas Med. Ctr., B-278400, Jan. 26, 1998,
98-1 CPD para. 120 at 6.

Technical approach was the most important evaluation factor, and the
non-price factors combined were significantly more important than price. RFP
at 69-70. In making his source selection, the SSA prepared a detailed
decision document comparing CTF's and 4-D's evaluated proposals and
explaining the advantages he found in the CTF system; as discussed above, we
find that the identified advantages are supported by the record. The SSA
then specifically found that, "based on the technological superiority of the
CTF system and the primary mission of NIMH, the overall cost difference is
well worth the expense." SSD para. 26. In other words, the SSA was aware of the
technical advantages of CTF's proposal, and specifically determined that
those advantages were worth CTF's higher cost. This is all that is required
for a proper tradeoff, and the fact that the protester believes the price
premium is too great is not sufficient to establish that the SSA's
determination was unreasonable. General Servs. Eng'g, Inc., B-245458, Jan.
9, 1992, 92-1 CPD para. 44 at 11 (award to offeror whose technically superior
proposal was 125 percent higher in cost than lower technically rated
proposal was proper).

The protest is denied.

Anthony H. Gamboa

General Counsel

Notes

1. A magnetometer measures the absolute value of the magnetic flux at a sole
detector coil. A gradiometer measures the change over space (gradient) of
the magnetic flux over two coils. AR, Tab 3, attach. A, para.para. 4-5.

2. Award originally was made to CCC/CTF. 4-D protested, challenging the
technical evaluation and price-technical tradeoff (B-286155). In response,
DLA took corrective action by amending the RFP to clarify the relative
weights of the evaluation criteria and to clarify its desire for the most
advanced, state-of-the-art MEG/EEG system. We dismissed that protest as
academic on September 25, 2000.

3. The 4-D systems are distinguished primarily by the type of sensors used.
[deleted]

4. The adjectival ratings have been abbreviated as follows: Highly
Acceptable (HA); Acceptable (A); strong point (s); and weak point (w).

5. After reviewing the agency report, 4-D withdrew earlier-raised protest
grounds concerning CTF's compliance with Food and Drug Administration
requirements and the past performance evaluation.

6. A hearing was convened as a technical roundtable to hear from the
protester's expert, the chairman of the TEP, the president of 4-D, and an
expert from CTF.

7. As explained at the hearing, the dynamic range is important because it
represents the maximum signal the system can tolerate and the resolution of
the signal. Tr. at 47.

8. Because the brain's magnetic signals are relatively weak, it is difficult
to measure them amid the background magnetic "noise." Noise cancellation, on
a very basic level, involves the MEG system's subtraction of reference
sensor information (noise) from the primary sensor information (brain signal
plus noise) to obtain a clearer record of the brain signal. Noise is
canceled by a combination of system features, including reference channels
and software.

9. In addition to the [deleted] channels, 4-D's system provided an
additional [deleted] channels, but these [deleted] were only derived, rather
than independent, channels. As conceded by 4-D, the [deleted] independent
channels are the only ones relevant to the evaluation. 4-D's Post-Hearing
Comments at 6.

10. CTF's third order gradiometer is a software-created, virtual gradiometer
that takes the primary sensor signal, in conjunction with the reference
channel, to compute a third spatial difference, resulting in additional
noise cancellation. AR, Tab 3, attach. A, para. 7. 4-D's assertion that this is
merely a marketing gimmick appears to be based on its lack of familiarity
with the proprietary details of the system; tellingly, 4-D's expert, who had
access to CTF's proposal and heard all testimony at the hearing, did not
dispute the existence of CTF's third order gradiometer.

11. 4-D also challenges the agency's evaluation of both offerors' proposed
system maintenance and product/customer support as "acceptable," arguing
that its maintenance and training were "palpably more extensive and
superior." Suppl. Protest at 5. In response, DLA fully explained its
rationale for determining that both offerors' proposals were adequate in
this area. Because 4-D's comments did not contain any rebuttal to the
agency's rationale, we consider this allegation abandoned. Analex Space Sys.
Inc.; PAI Corp., B-259024, B-259024.2, Feb. 21, 1995, 95-1 CPD para. 106 at 9.