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National Law Review
National Law Review
6/29/2026
When a Mentor-Protégé JV Falls Apart Mid-Procurement- What IBSS v. United States Means for Federal Contractors

When a Mentor-Protégé JV Falls Apart Mid-Procurement- What IBSS v. United States Means for Federal Contractors

Short summary

Federal court ruled that a dissolved mentor-protégé joint venture's large-business mentor lacks standing to protest contract awards to the joint venture, and that novation challenges fall outside bid protest jurisdiction. The decision provides critical guidance on interested party status in federal multiple-award IDIQ contracts for government contractors.

  • Large-business mentor cannot protest awards to dissolved joint venture entity where it did not submit an independent bid.
  • Court distinguished this case from CACI precedent: standing and merits are separable when challenging another bidder's award.
  • Novation disputes fall outside bid protest jurisdiction—must be addressed through agency procedures, not litigation.

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