Comptroller General

United States Government Accountability Office

Washington, DC 20548 

of the United States

DOCUMENT FOR PUBLIC RELEASE

The decision issued on the date below was subject to a 

GAO Protective Order. This redacted version has been 

approved for public release. 

Decision 

Matter of: SPAAN Tech, Inc. 

File: B-400406; B-400406.2 

Date: October 28, 2008 

Marc Van Allen, Esq., Kathy C. Weinberg, Esq., and Damien C. Specht, Esq., Jenner & 

Block LLP, for the protester. 

H. Jack Shearer, Esq., Kimberly M. Donham, Esq., and Young H. Cho, Esq., 

Department of Energy, for the agency. 

Peter D. Verchinski, Esq., and Guy R. Pietrovito, Esq., Office of the General Counsel, 

GAO, participated in the preparation of the decision. 

DIGEST 

Agency’s determination to not include protester’s lower technically rated, higher 

cost proposal in the competitive range--even though agency determined that two of 

the three higher technically rated offerors whose proposals were included in the 

range did not fully substantiate their indirect rates--was unobjectionable where 

agency otherwise reasonably concluded that protester’s proposal was not among the 

most highly rated offers. 

DECISION 

SPAAN Tech, Inc. of Chicago, Illinois protests the exclusion of its proposal from the 

competitive range under request for proposal (RFP) No. DE-RP02-08CH11469, issued 

by the Department of Energy (DOE) for technical support services. 

We deny the protest. 

The RFP provided for the award of a cost-plus-award-fee contract for technical 

support services with respect to such areas as the environment, safety, health 

facilities, and project and program management. The solicitation stated that award 

would be made on a “best value” basis, considering cost and the following weighted 

technical evaluation factors: technical understanding/approach (25%); management 

approach (30%); personnel qualifications/availability (25%); relevant corporate 

experience (10%); and past performance (10%). RFP §§ M.2, M.3. The technical 

evaluation factors were stated to be significantly more important than cost. 
The RFP did not specifically identify evaluation subfactors, but stated “components” 

that, although not weighted or individually rated, would be “considered as a whole in 

developing an overall point score for each criterion.” RFP § M.4. For example, 

under the technical understanding/approach factor, offerors were informed that the 

agency would evaluate the offerors’ approach for ensuring technical quality and their 

proposed quality assurance plans. Similarly, under the management approach 

factor, the solicitation stated that the offerors’ transition plans, as well as the firms’ 

ability to manage change, would be evaluated. Id. 

Detailed instructions were provided for the preparation of proposals under each of 

the evaluation factors. Offerors were instructed to submit their proposals in three 

volumes, consisting of technical and cost proposals and an “Offer and Other 

Documents” volume. RFP §§ L.29, M.2(b), M.6. With respect to the technical 

understanding/approach factor, the RFP instructed that offerors describe their 

approach[es] for ensuring technical quality (e.g. appropriateness, 

accuracy, completeness) of all of its work products and its 

understanding of the implications of such as they relate to the 

mission of the Office of Science. The offeror shall provide a 

summary and/or outline of its quality assurance plan and the role of 

the plan in ensuring quality work products. The offeror shall 

describe any related management efforts such as quality 

certifications (e.g. [International Organization for Standardization 

standards] or other). 

RFP § L.29(a)(3)(iii)(A). 

With respect to the cost factor, offerors were required to provide a “comprehensive 

fully-supported” proposal, which addressed all elements of cost applicable to the 

proposed effort.1

 RFP § L.29(a)(4)(ii)(C). Regarding the offerors’ proposed indirect 

rates, the solicitation required the offerors to 

[s]how the proposed rates by [contractor fiscal year] for all 

applicable burdens (e.g. fringe benefits, overhead, and general and 

administrative expenses). Identify the application base for each 

burden rate, and provide documentation regarding the basis for the 

proposed rates/factors (i.e. [forward pricing rate agreements], 

bidding rates, [Defense Contract Audit Agency] audits). In the event 

 

1

 The RFP provided that cost or pricing data was not required but that, “in 

accordance with [Federal Acquisition Regulation (FAR) §] 15.403-3 and [FAR §] 

15.403-5, information other than cost or pricing data is required to determine if 

proposed costs are reasonable, realistic, and reflect a clear understanding of the 

solicitation requirements.” RFP § L.29(a)(4)(i). 

Page 2 B-400406, B-400406.2 
the offeror does not have an approved forward pricing rate, provide 

details as to the composition of the base and pool costs that are 

being used to develop the proposed burdens. 

RFP § L.29(a)(4)(ii)(C)(3). Offerors were further informed that DOE would 

calculate, for each offeror’s proposal, an evaluated cost that may be adjusted as part 

of the evaluation of the cost proposal’s completeness, reasonableness, and realism. 

RFP § M.6. 

Seven offerors, including SPAAN, the incumbent contractor, submitted proposals, 

which were reviewed by the agency’s source evaluation board (SEB). Technical 

proposals received point scores of 0, 2, 5, 8, or 10 under each of the technical 

evaluation factors; the point scores were supported by narrative explanations 

describing the proposals’ respective strengths and weaknesses under the pertinent 

factors.2 These point scores were then weighted to reflect the relative weight 

assigned by the RFP to the applicable factor. 

With regard to SPAAN’s technical proposal, the SEB found that the proposal had a 

“significant weakness” under the technical understanding/approach factor, because 

SPAAN did not address specifically how it would ensure technical quality and had 

failed to provide a summary or outline of its quality assurance plan, as required by 

the solicitation; accordingly, SPAAN’s technical proposal received only two points 

under this evaluation factor. Under the most important management approach 

factor, SPAAN’s proposal received only five points, because the SEB found that 

SPAAN had provided little rationale for its proposed organizational structure and the 

firm’s organization chart was unclear as to the lines of program management; the 

SEB also noted some strengths, including that SPAAN, as the incumbent contractor 

believed that a transition plan was not necessary but the firm had nevertheless 

 

2

 The agency’s rating plan established standards for assigning point scores. For 

example, a proposal would receive eight points under an evaluation factor, where it 

was determined that the offeror had addressed all aspects of the factor, was highly 

capable/experienced, and had a high probability of success and that the offeror had 

few weaknesses and no deficiencies. A proposal would receive two points, on the 

other hand, where the offeror was found to have not addressed all aspects of the 

factor and was somewhat capable/experienced and where some significant 

weaknesses were noted or where there were “one or more deficiencies . . . noted 

including those triggered by significant weaknesses.” AR, Tab 2, Rating Plan 5-6. 

The rating plan also defined what was considered to be a major or minor strength, a 

weakness or significant weakness, or a deficiency. For example, a “significant 

weakness” was defined to be “a flaw that appreciably increases the risk of 

unsuccessful contract performance.” Id. at 7. 

Page 3 B-400406, B-400406.2 
provided a good description of a transition team and timelines for transition.3

 With 

respect to the remaining three technical evaluation factors, the SEB assigned points 

scores of 8, 10, and 8 points, respectively. In all, SPAAN’s proposal received 33 of 

the available 50 points, which when weighted resulted in an evaluated point score of 

5.8 points. AR, Tab 5, Initial SEB Report, at 23-24. 

Cost proposals were also evaluated for completeness, reasonableness, and realism. 

In its cost realism evaluation, the SEB made adjustments to each of the offerors’ cost 

proposals in order to calculate a most probable cost to the agency. These 

adjustments included corrections for any calculation errors, adjustments to direct 

labor rates, and an examination of the offerors’ proposed indirect rates (including 

the basis for each offeror’s fringe, overhead, and general and administrative rates). 

With regard to the offerors’ proposed indirect rates, the agency found that 

[f]ive of the seven offerors . . . did not provide complete information 

to allow the Government to determine the adequacy of the proposed 

indirect rates, nor was recent rate information available from [the 

Defense Contract Audit Agency]. However, for two of these five . . . 

partial information was provided . . . . For purposes of this analysis, 

and absent sufficient data to the contrary, the Government utilized 

the indirect rates as proposed for those offerors and subcontractors 

that did not provide sufficient back-up documentation. In instances 

where partial information was utilized, adjustments were made 

when the partial information so dictated. 

AR, Tab 5, Initial SEB Report, at 29-30. 

SPAAN was one of the two offerors that were found to have adequately supported 

the firms’ proposed indirect rates. See AR, Tab 6, Competitive Range Determination, 

at 11. In its cost realism evaluation, DOE made only minor adjustments to SPAAN’s 

proposed costs, which resulted in an upward adjustment of only $109. 

 

3

 Under the agency’s rating plan, a proposal received five points where the offeror 

was found to have addressed all aspects of the factor, was capable/experienced, and 

had a good probability of success and where the offeror had only a few weaknesses 

(none of which were significant) and no deficiencies. AR, Tab 2, Rating Plan, at 5-6. 

Page 4 B-400406, B-400406.2 
The SEB ranked the offerors’ initial proposals, as follows: 

Offeror Technical Score Evaluated Cost 

A 8.5 $8,827,421 

B 7.55 $7,695,261 

C 7.45 $7,262,680 

D 6.2 $10,712,345 

SPAAN 5.8 $8,399,832 

E 5.3 $9,674,118 

F 2.6 $6,966,441 

Id. at 7. 

The contracting officer determined that the agency would conduct discussions with 

the most highly rated offerors, which the contracting officer concluded were offerors 

A, B, and C. AR, Tab 6, Competitive Range Determination, at 15. With regard to 

these three offerors, the contracting officer noted that offerors A and B had failed to 

provide adequate information to allow the agency to analyze the firms’ proposed 

indirect rates, but that discussions would allow the agency to obtain this 

information.4 Id. at 11-13. With regard to SPAAN’s proposal, the contracting officer 

determined that, although SPAAN’s proposal had the fourth lowest evaluated cost, 

this did not offset the number of weaknesses evaluated in the firm’s technical 

proposal. In particular, the contracting officer noted, among other things, the 

significant weakness assessed in SPAAN’s proposal for its failure to address how the 

firm was going to ensure technical quality and its lack of a quality assurance plan 

outline or summary; the contracting officer also noted SPAAN’s assessed 

weaknesses with respect to its lack of rationale for its organization structure and to 

its proposal of a senior project controls specialist that did not satisfy the 

solicitation’s education and experience requirements. Id. at 13-14. 

 

4

 With regard to Offeror A, DOE found that, although the firm did not have forward 

pricing rates and had not provided its calculations for its indirect rates, the firm 

stated in its proposal that its indirect rates were consistent with its historical rates 

that had been reviewed by the Defense Contract Audit Agency. In addition, 

Offeror A explained its methodology for calculating the firm’s expense pools and 

allocation bases for its indirect rates, which DOE found to be reasonable. See AR, 

Tab 10, Probable Cost Analysis, at 29. With regard to Offeror B, DOE found that the 

firm only provided its indirect rate percentages and had not adequately explained its 

methodology for calculating indirect rates; in this regard, Offeror B stated in its 

initial proposal that the firm was undergoing their first audit by the Defense Contract 

Audit Agency. Id. at 42. 

Page 5 B-400406, B-400406.2 
SPAAN’s proposal was excluded from the competitive range, and following a 

debriefing, SPAAN filed this protest with our Office. 

We will review an agency’s evaluation and exclusion of a proposal from the 

competitive range for reasonableness and consistency with the solicitation criteria 

and applicable statutes and regulations. Novavax, Inc., B-286167, B-286167.2, Dec. 4, 

2000, 2000 CPD ¶ 202 at 13. Contracting agencies are not required to retain in the 

competitive range proposals that are not among the most highly rated or that the 

agency otherwise reasonably concludes have no realistic prospect of being selected 

for award. FAR § 15.306(c)(1); D & J Enter., Inc., B-310442, Dec. 13, 2007, 2008 CPD 

¶ 8 at 2. We find from our review of the record, as explained below, no basis to 

object to the agency’s evaluation of proposals or competitive range determination. 

SPAAN challenges the agency’s evaluation of the firm’s proposal under the technical 

understanding/approach, management approach, and past performance factors and 

contends that its proposal should have been found to be one of the most highly rated 

and included in the competitive range.5

 With respect to the evaluation of its 

proposal under the technical understanding/approach factor, SPAAN disagrees that 

it did not adequately discuss how the firm would ensure technical quality in 

performing the contract and that it had not adequately discussed its quality 

assurance plan.6 In this regard, SPAAN cites certain pages of its proposal as 

assertedly demonstrating the firm’s approach to ensuring technical quality. See

Protester’s Comments at 12-13. SPAAN also argues that, as it indicated in its 

proposal, SPAAN, as the incumbent contractor, had successfully integrated its 

quality assurance plan with the agency’s quality control and quality assurance 

requirements, which SPAAN contends satisfies the RFP’s requirement to describe

how the firm would ensure technical quality. SPAAN concludes that, absent DOE’s 

allegedly unreasonable evaluation, the firm’s proposal would have received more 

an the two points it received under this factor. 

 

th

5

 SPAAN does not protest the agency’s evaluation of any of the offerors’ technical 

proposals that were included in the competitive range. 

6

 SPAAN states in its protest that, at the debriefing, DOE informed SPAAN that a 

substantial weakness was assigned under the technical understanding/approach 

factor because SPAAN had presented a “standardized” approach rather than one 

specifically tailored to DOE, and SPAAN argues that its proposal provided a tailored 

approach. See Protester’s Comments at 11. Although DOE does not dispute 

SPAAN’s version of what the firm was told in its debriefing, DOE states that the 

significant weakness assessed in SPAAN’s proposal under this factor was based 

upon the firm’s failure to address how the offeror would ensure technical quality. 

The contemporaneous record supports the agency’s explanation. 

Page 6 B-400406, B-400406.2 
DOE contends that SPAAN’s proposal addressed a “traditional program 

management-based approach to the work (e.g., implementing internal project 

controls, schedule control, tracking performance indicators)” and identified the 

work to be performed but did not substantively address how the firm would ensure 

technical quality. See AR, Tab 5, Initial SEB Report at 43. In this regard, DOE also 

notes that, despite the solicitation’s explicit instructions, SPAAN failed to provide an 

outline or summary of its quality assurance plan and that it is an offeror’s obligation 

to prepare a proposal that adequately addresses the solicitation’s requirements. 

We agree with DOE that an offeror bears the burden of submitting an adequately 

written proposal, and that it runs the risk that the firm’s proposal will be evaluated 

unfavorably when it fails to do so. See American Ordnance, LLC, B-292847 et al., 

Dec. 5, 2003, 2004 CPD ¶ 3 at 4. Here, we find from our review of SPAAN’s techn

proposal, including those parts to which SPAAN cites in its comments, tha

provided little discussion of how it would ensure technical quality (that is, little 

discussion of how SPAAN would ensure the “appropriateness, accuracy, 

completeness” of its work products, as required by the RFP). We also find that 

SPAAN did not provide an outline or summary of its quality assurance plan, alth

this too was required by the RFP

ical 

t SPAAN 

ough 

. Given these shortcomings in SPAAN’s proposal, 

e cannot say that DOE acted unreasonably in assessing these failures to be a 

 should 

sal 

w

significant proposal weakness. 

Although its true that SPAAN referenced in its proposal the firm’s incumbent 

performance, including its integration of a quality assurance plan, we disagree with 

SPAAN’s apparent belief that, because the firm, as the incumbent contractor, had 

successfully implemented a quality assurance plan in its prior contract, DOE

accept SPAAN’s experience in this regard in lieu of an adequately written propo

addressing all of the solicitation’s requirements.7

 See HealthStar VA, PLLC, 

 

7

 SPAAN contends that, in addition to the evaluation of proposals, the solicitation 

also required DOE to evaluate offerors’ “anticipated performance.” Specifically, 

SPAAN points to an RFP provision stating that DOE will assess “what the strengths 

and weaknesses between or among competing technical proposals indicate from the 

standpoint of (1) what the difference might mean in terms of anticipated 

performance . . . .” RFP § M.2(c). SPAAN argues that, as the incumbent, any 

evaluation of other offerors’ “anticipated performance” would show that their higher 

technical scores would not result in any differences with SPAAN’s current 

performance. We find from our review of the record that DOE did assess the relative 

merits of the firms’ proposals, including their assessed proposal strengths and 

weaknesses, and we find that this in fact was an assessment of the firms’ 

“anticipated performance.” We think that SPAAN’s argument in this regard is no 

more than mere disagreement with the agency’s judgment concerning the relative 

merits of the firms’ proposals, which does not show that judgment to be 

unreasonable. 

Page 7 B-400406, B-400406.2 
B-299737, June 22, 2007, 2007 CPD ¶ 114 at 2; Interactive Commc’n Tech., Inc., 

B-271051, May 30, 1996, 96-1 CPD ¶ 260 at 2. In this regard, offerors’ past 

erformance was evaluated under another evaluation factor, for which SPAAN’s 

or, 

ion 

ts 

ge 

e 

 major strength, rather than a minor strength, for the fact that, as the 

cumbent contractor, it posed no transition risk.8

 See

p

proposal received credit for its performance of the incumbent contract. 

SPAAN also protests DOE’s evaluation of the firm’s proposal under the management 

approach factor, for which SPAAN’s proposal received five points. Under this fact

DOE noted as minor strengths SPAAN’s description of its project manager’s decis

making authority and the fact that the firm, as the incumbent contractor, may not 

require a transition plan (although SPAAN also provided a good description of a 

transition team and transition timelines); DOE also noted as a weakness, however, 

that SPAAN had provided little rationale for its organizational structure and that i

proposal was unclear as to lines of program authority. SPAAN does not challen

the agency’s assessed weakness in its proposal, but contends that it should hav

received a

in Protester’s Comments 

e 

ines. 

of 

five points was unreasonable, given the unchallenged weakness concerning 9

at 12-13. 

We find no basis to object to DOE’s evaluation of SPAAN’s proposal under this 

factor. Here, the agency specifically recognized, as a minor proposal strength, th

protester’s incumbency status with respect to the need for a transition plan and 

credited the firm for its discussion of a transition team and transition timel

Although SPAAN believes that it should have received more credit for its lack 

“transition risk,” we do not think that this disagreement with the agency’s 

assignment of a minor strength demonstrates that the agency’s assignment of 

organizational structure also assessed in the firm’s proposal under this factor. A

 

8

 In its protest, SPAAN also argued that it should have received a major strength 

under the management approach factor for the firm’s ability to manage change.

agency re

 The 

sponded to these arguments in its report, and SPAAN failed to address the 

agency’s response. Accordingly, we consider this argument to have been abandoned. 

Citrus College; KEI Pearson, Inc., B-293543 et al., Apr. 9, 2004, 2004 CPD ¶ 104 

at 8 n.4. 

9

 Similarly, SPAAN objects to the agency’s evaluation of the firm’s proposal under the

past performance factor, for which SPAAN’s proposal received eight points. SPAAN 

contends that, given its high performance ratings, SPAAN should have received 

10 points. Given the 10% weighting assigned to this factor, increasing SPAA

performance score by two points would only increase SPAAN’s weighted point sco

by .2. We do not find any reasonable possibility that this small increase in the firm’s 

overall weighted point score would change the agency’s competitive range 

determination. In any event, as discussed

N’s past 

re 

 above, the agency’s decision to exclude 

PAAN’s proposal from the competitive range was not based on a mechanical review 

(continued...) 

S

Page 8 B-400406, B-400406.2 
protester’s mere disagreement with the agency’s judgment does not establish that an 

evaluation was unreasonable. UNICCO Gov’t Servs., Inc., B-277658, Nov. 7, 1997, 

97-2 CPD ¶ 134 at 7. 

SPAAN also complains, citing to our decision in Global, A 1st Flagship Co., B-297235, 

B-297235.2, Dec. 27, 2005, 2006 CPD ¶ 14, that the agency’s competitive range 

determination was unreasonable because it was based upon an inadequate cost 

realism evaluation. 

It is well established that an agency may not exclude a technically acceptable 

proposal from the competitive range without meaningful consideration of cost or 

price of that proposal to the government. See Kathpal Tech., Inc.; Computer & 

Hi-Tech Mgmt., Inc., B-283137.3 et al., Dec. 30, 1999, 2000 CPD ¶ 6 at 9, aff'd, 

Department of Commerce-- Request for Modification of Recommendation, 

B-283137.7, Feb. 14, 2000, 2000 CPD ¶ 27. Accordingly, we found in Global that an 

agency could not reasonably exclude the protester’s “highly acceptable” technical 

proposal solely on the basis of the protester’s higher evaluated cost, where the 

agency’s cost realism analysis was not “reasonably thorough, accurate, and 

complete” and the cost realism analysis reflected material errors and flawed 

assumptions. See Global, A 1st Flagship Co., supra, at 5. 

Here, unlike in Global, we find that the agency conducted a “reasonably thorough, 

accurate, and complete” cost realism evaluation. That is, the record shows that DOE 

assessed the cost realism of all of the offerors’ proposals, see, e.g., AR, Tab 5, Initial 

SEB Report, at 27-30, and that the contracting officer considered the offerors’ 

evaluated costs in determining which offers were most highly rated. See AR, Tab 6, 

Competitive Range Determination, at 10-15. It was based upon this evaluation that 

DOE determined that Offerors A and B had not sufficiently supported their proposed 

indirect rates. 

Apart from the agency’s acceptance of these offerors’ indirect rates for the purpose 

of including these firms in the competitive range, SPAAN does not otherwise 

contend that DOE’s cost realism evaluation reflected material errors or flawed 

assumptions. Rather, the crux of SPAAN’s complaint is that DOE concluded that the 

proposals of Offerors A and B were most highly rated, even though the agency also 

found that these firms could not substantiate their initial proposals’ indirect rates. 

We do not find the fact that a proposal contains weaknesses or deficiencies that may 

be addressed during discussions requires the exclusion of that proposal from the 

 

(...continued) 

of points, but reflected the agency’s significant concerns with SPAAN’s propos

resulted in SPAAN’s lower point scores. 

al that 

Page 9 B-400406, B-400406.2 
competitive range. Rather, a competitive range is established for the purpose of 

cies, 

determining which offerors will receive discussions and to provide those offerors

with an opportunity to revise proposals and address weaknesses and deficien

among other things. See FAR § 15.306(c), (d). Thus, we find that DOE could 

reasonably include the proposals of Offerors A and B in the competitive range to 

conduct discussions with these firms with respect to their proposed indirect rates. 

Moreover, we also find reasonable the agency’s conclusion that the proposa

Offerors A & B were among the most highly rated offers for inclusion in the 

competitive range and that SPAAN’s proposal was not. As noted above, DOE 

reasonably found that SPAAN’s technical proposal was not as highly rated as the 

three offerors whose proposals were included in the competitive range; in fact, DOE

found that SPAAN’s proposal was only the fifth highest rated offer of the seven 

proposals received.

ls of 

e offerors. 

 making this judgment, the contracting officer was fully aware that Offerors A and 

obtain 

10 When considered with the firms’ evaluated costs, the 

contracting officer concluded that although SPAAN’s evaluated cost was lower than

that of Offeror A, SPAAN’s proposal was still not one of the most highly rated offers, 

given the significant concerns the agency had with SPAAN’s proposal, which was 

much lower rated technically than the proposals of the competitive rang

In

B had not substantiated their indirect rates but the contracting officer also 

concluded that these firms’ indirect rates were “a relatively small portion of [their] 

overall costs” and that discussions with these firms would allow the agency to 

information necessary to substantiate their indirect rates. See Contracting Officer’s 

Statement at 25; AR, Tab 6, Competitive Range Determination, at 12-13. 

SPAAN also complains that DOE did not consider the extent to which SPAAN could 

correct “information deficiencies” in its proposal and therefore the inclusion o

proposals of Offerors A and B in the competitive range to allow these firms to 

substantiate their indirect rates reflects dispar

f the 

ate and unequal treatment. SPAAN’s 

roposal, however, was not excluded from the competitive range because the 

ies or weaknesses that could not be corrected but because the 

ontracting officer concluded that SPAAN’s proposal was not among the most highly 

ring both technical merit and cost. As noted above, this 

 

p

proposal had deficienc

c

rated offers, conside

10 SPAAN also argues that the failure of Offerors A and B to substantiate the firms’ 

proposed indirect rates should have caused DOE to downgrade the firms’ technical 

proposals. The RFP provided that an “unrealistic, unreasonable, or incomplete 

Cost/Price proposal may be evidence of the Offeror’s lack of, or poor understanding 

of, the requirements of the solicitation” and may affect the offeror’s technical rating. 

See RFP § M.6. The agency responds that it did not find a disparity between the 

firms’ technical and cost proposals that would have indicated a lack of, or poor 

understanding of, the RFP’s requirements. SPAAN has not shown the agency’s 

judgment to be unreasonable. 

Page 10 B-400406, B-400406.2 
Page 11 B-400406, B-400406.2 

judgment is specifically permitted by FAR § 15.306(c)(1). We find no evidence of 

disparate or unequal treatment in this record. 

28BThe protest is denied. 

29BGary L. Kepplinger 

General Counsel