APPELLANT DISMISSED FOR LACK OF STANDING:
February 9, 2026
CBCA 8362
GEOFFREY WATTIKER AND BRITTANI WATTIKER,
Appellants,
v.
GENERAL SERVICES ADMINISTRATION,
Respondent.
Geoffrey Wattiker and Brittani Wattiker, pro se, Dallas, TX.
Anne C. McDermott, Office of General Counsel, General Services Administration,
Philadelphia, PA, counsel for Respondent.
Before Board Judges LESTER, KULLBERG, and O’ROURKE.
KULLBERG, Board Judge.
Although the respondent has not raised an objection, the Board raises sua sponte the
issue of whether Geoffrey Wattiker has standing to appear before the Board as an appellant,
alongside his wife, Brittani Wattiker, in this appeal.  On February 26, 2025, the Board
docketed this appeal as Geoffrey Wattiker and Brittani Wattiker v. General Services
Administration, CBCA 8362, after the Wattikers jointly filed a notice of appeal challenging
the contracting officer’s “deemed denial” of claims involving alleged misrepresentations in
three General Services Administration (GSA) auction notices, in response to which Brittani
Wattiker had submitted winning bids.  The three contracts at issue in this appeal were issued
to and signed by only one of the appellants, Brittani Wattiker, and the contracting officer’s


CBCA 8362 2
final decision, which was issued after this appeal was filed, was addressed only to Brittani
Wattiker. 
“[T]o invoke the Board’s jurisdiction in a contract appeal under the [Contract Disputes
Act (CDA), 41 U.S.C. §§ 7101-7109 (2018)], [an] appellant must allege facts sufficient to
show that, among other things, it is a ‘contractor’ as that term is defined in the CDA.” 
Kristin Allred v. Department of Veterans Affairs, CBCA 4952, 15-1 BCA ¶ 36,108, at
176,282; see 41 U.S.C. § 7104(a) (only a “contractor” may file an appeal of a contracting
officer’s decision with a board of contract appeals).  The CDA defines a contractor as “a
party to a Federal Government contract other than the Federal Government.”  41 U.S.C.
§ 7101(7).  Additionally, the CDA provides that “[e]ach claim by a contractor against the
Federal Government relating to a contract shall be submitted to the contracting officer for
a decision.”  Id. § 7103(a)(1).  The Board’s rules state that an “‘appellant’ is the contractor
filing an appeal.”  Rule 1(b) (48 CFR 6101.1(b) (2024)).  Based on the record, Geoffrey
Wattiker is not a named party (i.e., not a contractor) on the contracts at issue and, therefore,
cannot be an appellant.  Accordingly, Brittani Wattiker is the only person who can be the
appellant in this appeal.
Additionally, only Brittani Wattiker may appear as a pro se representative in this
appeal.  The Board’s rules provide, in pertinent part, that “[a]n appellant, petitioner, or
applicant may appear before the Board through an attorney.  An individual appellant,
petitioner, or applicant may appear for himself or herself.”  Rule 5(a)(1).  The Board has
recognized that, while a pro se appellant may represent himself or herself, no other
non-lawyer, including family members, may represent a pro se appellant.  Sylvan B. Orr v.
Department of Agriculture, CBCA 5299, 16-1 BCA ¶ 36,479, at 177,744.  In addition, a
pro se appellant is responsible for signing all papers, pleadings, and motions filed with the
Board.  Id. at 177,745.
For the foregoing reasons, Gregory Wattiker is dismissed as an appellant in this
appeal.  The case caption will be revised to identify Brittani Wattiker as the sole appellant
and representative in this appeal.
    H. Chuck Kullberg         
H. CHUCK KULLBERG
Board Judge

CBCA 8362 3
We concur:
    Harold D. Lester, Jr.         Kathleen J. O’Rourke     
HAROLD D. LESTER, JR. KATHLEEN J. O’ROURKE
Board Judge Board Judge