United States Government Accountability Office 

Washington, DC 20548 

Comptroller General

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: Trofholz Technologies, Inc. 

File: B-404101 

Date: January 5, 2011 

Steven N. Tomanelli, Esq., for the protester. 

Michael G. McCormack, Esq., Col. Mark S. Teskey, and Paul H. Blackwell, Jr., Esq., 

Department of the Air Force, for the agency. 

Christina Sklarew, Esq., and Guy R. Pietrovito, Esq., Office of the General Counsel, 

GAO, participated in the preparation of the decision. 

DIGEST 

Agency’s evaluation and selection decision are unobjectionable, where the 

evaluation and the award determination are reasonable and consistent with the 

solicitation’s stated evaluation criteria. 

DECISION 

Trofholz Technologies, Inc., of Rocklin, California, protests the award of a contract 

to Spiral Solutions and Technologies, Inc., of Omaha, Nebraska, under request for 

proposals (RFP) No. FA7037-10-R-1001, issued by the Department of the Air Force 

for maintenance and support services for the Air Force Language Portal. 

We deny the protest. 

BACKGROUND 

The Air Force Language Portal is used to track the training status and capabilities of 

Air Force linguists and to provide online training in foreign languages and cultures. 

The portal provides language and culture materials on unclassified and classified 

(secret and top secret) networks, supporting as many as 50,000 linguists. 

Contracting Officer’s (CO) Statement at 2; RFP, Statement of Work (SOW), at 46. 

The RFP, issued as a section 8(a) competitive procurement, provided for the award 

of a contract for a base year and 2 option years for the maintenance and 

enhancement of the agency’s system hardware and for the enhancement of the 

language portal website. SOW at 46-47. The contractor is required to ensure that 

access to the portal is available on 24-hour per day, 365-days per year basis. Offerors 
were informed that the contractor must deliver and deploy the classified systems 

within 6 weeks of the contractor’s receipt of required hardware and software from 

the agency. Id. at 47. Offerors were also informed that maintenance of the portal’s 

classified and unclassified servers would include “updating databases, creating 

queries and reports, Automated Data-Processing Equipment (ADPE) accountability 

and uploading and updating language and cultural resources.” Id. 

The RFP provided that award would be made on a best value basis, considering the 

following evaluation factors, listed in descending order of importance: mission 

capability, past performance, and cost/price. The non-cost/price factors were stated 

to be, when combined, significantly more important than cost or price. RFP at 39. 

The mission capability factor included two subfactors, basic needs and management 

approach, which were listed in descending order of importance. Offerors were 

informed that, under the basic needs subfactor, the agency would evaluate, among 

other things, the offeror’s understanding of, and demonstrated ability to, meet the 

SOW requirements, and whether its proposed personnel had requisite expertise. 

RFP at 40. Under the management approach subfactor, the agency would evaluate 

an offeror’s concept for minimizing management oversight and such management 

abilities as staffing and coordinating work. Id. at 41. 

The RFP provided that the mission capability factor would be assessed for both 

technical merit and for performance risk. The technical rating would assess an 

offeror’s demonstrated understanding of the SOW requirements, and would take into 

account such elements as the offeror’s technical expertise and planned approach to 

the SOW requirements. The risk rating was to focus on the weaknesses associated 

with an offeror’s proposed approach, and would consider any potential for 

disruption of schedule, increased cost, and similar elements that could result in 

unsuccessful contract performance. Id. at 40-42. 

The agency received proposals from four offerors, including Trofholz (the incumbent 

contractor) and Spiral. Trofholz’s and Spiral’s proposals were evaluated as follows: 

Trofholz Spiral 

Mission capability Technical Risk Technical Risk 

Basic needs Acceptable Moderate Exceptional Low 

Management approach Acceptable Low Acceptable Low 

Past performance Substantial Confidence Substantial Confidence 

Price $5,435,735.20 $5,478,364.80 

Agency Report (AR), Tab 9, Best Value Determination, at 28. 

Trofholz’s “acceptable” and “moderate risk” ratings under the basic needs subfactor 

reflected the evaluators’ judgment that, although Trofholz (which had created the 

current portal) demonstrated a thorough understanding of the future vision for the 

Page 2 B-404101 
language portal and of blending technology and language learning, its proposal 

contained some weaknesses. Specifically, the evaluators found Trofholz did not 

address ADPE accountability in its proposal. AR, Tab 8, Consensus Technical 

Evaluation, at 4. In addition, the evaluators found that Trofholz had not adequately 

addressed the use of the classified Secret Internet Protocol Router Network 

(SIPRNet) and the Joint Worldwide Intelligence Communications System (JWICS) 

networks in its proposal. Moreover, the evaluators found that Trofholz proposed 

providing support for the classified networks beginning April 2011, or 6 months into 

the basic contract performance period, whereas the solicitation requires 12 months 

of support. Id. at 5. 

 

Spiral’s “exceptional” and “low risk” ratings under the basic needs subfactor 

reflected the evaluators’ judgment that Spiral had demonstrated a thorough 

understanding of the requirements, had experience in deploying software on 

classified systems, and proposed instructors whose experience far exceeded the 

SOW requirements. Id. at 2. The evaluators identified no weaknesses in Spiral’s 

proposal under this subfactor. 

 

The CO, who was the source selection authority, reviewed the evaluation findings 

and concluded that Spiral’s higher-priced proposal offered the best value to the 

government. Specifically, the CO noted various aspects of Spiral’s proposal that the 

CO considered to be superior, such as its staff’s extensive experience in military 

management and knowledge of management processes; the firm’s approach to team 

development; its availability of information technology and foreign language 

specialists; and its high employee retention rates. Id. at 28. The CO found that 

Spiral’s higher technical merit outweighed Trofholz’s slightly lower price. In this 

regard, the CO noted that the difference between Spiral’s and Trofholz’s prices was 

only $42,629.60, or about 1 percent. Id. at 28-29. 

The Air Force made award to Spiral. Following a debriefing, Trofholz filed this 

protest with our Office. 

DISCUSSION 

Trofholz challenges the agency’s evaluation of its proposal for the basic needs 

subfactor under the mission capability factor, arguing that it should not have been 

downgraded for its approach to providing SIPRnet and JWICS support or for 

ensuring ADPE accountability. 

 

In reviewing protests of alleged improper evaluations and source selection decisions, 

it is not our role to reevaluate submissions; rather, we examine the record to 

determine whether the agency’s judgment was reasonable and in accord with the 

stated evaluation criteria and applicable procurement laws and regulations. Panacea 

Consulting, Inc., B-299307.4, B-299308.4, July 27, 2007, 2007 CPD ¶ 141 at 3. A 

protester’s mere disagreement with an agency’s judgment is not sufficient to 

Page 3 B-404101 
establish that an agency acted unreasonably. Entz Aerodyne, Inc., B-293531, 

Mar. 9, 2004, 2004 CPD ¶ 70 at 3. 

With regard to the Air Force’s assessed concern with Trofholz’s approach to the 

classified networks, the crux of protester’s arguments is that the agency 

misunderstood Trofholz’s proposal. Specifically, Trofholz argues that, although it 

proposed providing support for the classified networks beginning 6 months into 

contract performance (based upon Trofholz’s belief that this was when the language 

portal would be approved to work on these systems, see Trofholz’s Technical 

Proposal at 37), Trofholz recognized that it was obligated to provide language portal 

support for the SIPRnet and JWICS networks, at no additional cost to the agency, at 

whatever point the language portal became available on these networks. Comments 

at 3. In this regard, Trofholz cites to a number of general statements in its proposal 

where the firm stated it would perform all SOW requirements. Id. at 4, citing

Trofholz’s Technical Proposal at 36 (Trofholz “is prepared to meet the requirements 

of the solicitation and SOW upon award”). 

We find from our review of the record that the Air Force reasonably assessed a 

weakness under the basic needs subfactor for Trofholz’s failure to adequately 

address its support for the classified networks and its failure to propose providing 

this support within 6 weeks of the contractor’s receipt of required hardware and 

software from the agency, as required by the RFP. Apart from Trofholz’s general 

statements that it would comply with the contract requirements, its proposal does 

not describe the support it would provide for these classified networks.1

 The 

proposal also does not state, as Trofholz now contends, that the firm would provide 

support for the classified networks before April 2011.2

 To the extent that Trofholz 

believes otherwise, it is an offeror’s responsibility to submit an adequately written 

proposal that demonstrates the merits of its approach; an offeror runs the risk of 

 

1

 Trofholz’s protest arguments do not specifically address the Air Force’s evaluation 

concern that Trofholz failed to adequately address the requirements for the language 

portal to reside on the SIPRnet and JWICS networks. 

2

 Trofholz also argues that Spiral’s approach to providing support for the classified 

networks was essentially similar, citing a sentence from Spiral’s proposal that states, 

that “[u]pon contract award (and once the government delivers hardware 

accreditation), our Program Manager will develop an augmentation plan.” See

Comments at 5, citing Spiral’s Technical Proposal at 7. This argument, however, 

ignores the remainder of Spiral’s proposal, which in numerous places describes the 

firm’s support for the classified networks and specifically states it “will take into 

account the specifics of the system deployment to deliver the existing system to the 

Secret and [Top Secret/Sensitive Compartmented Information] networks within 6 

weeks of receipt of required hardware and software from the government.” Spiral’s 

Technical Proposal at 8. 

Page 4 B-404101 
having its proposal downgraded or rejected if the proposal is inadequately written. 

James Constr., B-402429, Apr. 21, 2010, 2010 CPD ¶ 98 at 4-5. 

 

Trofholz also disagrees with the agency’s assessment that the protester did not 

address ADPE accountability in its proposal.3

 Specifically, Trofholz cites a sentence 

in the past performance portion of its proposal, which states that Trofholz has 

managed and protected equipment within its control, “including account and 

inventory control using the USAF Automated Data Processing Equipment 

accountability system.” Protest at 8-9, citing Trofholz’s Technical Proposal at 78. 

Also, Trofholz notes various sections of its mission capability proposal, which it 

claims “describe the ADPE accountability tasks” that Trofholz would perform. 

Trofholz argues that, although these statements do not use the phrase “ADPE 

accountability,” they describe tasks, which Trofholz argues the evaluators should 

have recognized as comprising ADPE accountability. For example, Trofholz quotes 

a statement that its engineers “have implemented a standardized process to ensure 

the detailed system configuration is well-documented and maintained” and asserts 

that documentation of the “detailed system configuration” requires that all ADPE be 

accounted for in terms of its age, condition, location and usage. In another example, 

Trofholz states that it has “assumed full responsibility for the Language Portal’s 

configuration and accreditation,” and posits that “full responsibility” would 

necessarily include maintaining accountability of the ADPE platforms supporting the 

Language Portal. Comments at 8. 

The record shows that the Air Force reasonably found that Trofholz failed to address 

ADPE accountability in its proposal. Although Trofholz now cites to a number of 

general statements in its proposal that it asserts comprise ADPE accountability, no 

part of its proposal specifically addresses this SOW requirement. Again, it it is an 

offeror’s responsibility to submit an adequately written proposal that demonstrates 

the merits of its approach. James Constr., supra, at 4-5; see also Managed Care 

Concepts, LLC, B-402750, July 15, 2010, 2010 CPD ¶ 164 at 4 (no matter how 

competent an offeror may be, the technical evaluation must be based on information 

included in the firm’s proposal). Given that the RFP stated that the agency would 

evaluate under the basic needs subfactor an offeror’s understanding of, and ability to 

meet, the SOW requirements, we find reasonable the agency’s identification of the 

lack of any direct explanation of the firm’s approach to ADPE accountability as a 

proposal weakness. 

Trofholz argues that the agency evaluated its and Spiral’s proposals disparately with 

respect to ADPE accountability. Specifically, Trofholz contends that Spiral’s 

 

3

 Trofholz also argues in its comments that the RFP failed to fairly inform offerors of 

the need to address ADPE accountability. Comments at 5-6. We find that challenge 

to be untimely, inasmuch as Trofholz knew the basis of this protest allegation when 

it filed its initial protest. 

Page 5 B-404101 
Page 6 B-404101 

proposal merely recites Air Force procedures regarding ADPE accountability, which 

Trofholz asserts is no different than the general statements identified above. We find 

no merit to Trofholz’s arguments in this regard. Unlike the protester’s proposal, 

Spiral specifically commits in its proposal to perform ADPE accountability in 

accordance with Air Force requirements and describes how it will do so. See

Spiral’s Technical Proposal at 13. Simply stated, we do not find that the Air Force 

disparately evaluated the two firms’ proposals with respect to ADPE accountability. 

Trofholz also argues that the agency did not separately assess technical merit and 

risk in its evaluation of the mission capability factor, as provided in the RFP. The 

crux of this argument is that the agency improperly based its risk rating for the basic 

needs subfactor upon Spiral’s technical rating for this subfactor, and in so doing, 

“double counted” the technical rating. 

Spiral’s risk rating under the basic needs subfactor was “evaluated as LOW due to 

the exceptional rating for Basic Needs and the acceptable rating for Management 

Approach.” See AR, Tab 8, Technical Evaluation Consensus, at 1. This is consistent 

with the RFP’s evaluation methodology, which stated that the mission capability risk 

rating would focus “on the weaknesses associated with an offeror’s proposed 

approach.” RFP at 41. Here, the agency identified multiple strengths in Spiral’s 

technical approach and no weaknesses under this subfactor. Although the 

evaluators did not specifically state that the exceptional approach and lack of 

weaknesses would translate into little potential to cause disruption, increased cost, 

or degradation of performance,4

 the import of such a technical rating (with no 

weaknesses) is that there would be little potential for disruption, increased cost, or 

degradation of performance. Similarly, Trofholz’s identified weaknesses, which the 

CO concluded increased the risk of nonperformance, see AR, Tab 9, Best Value 

Determination, at 29, merited a moderate risk rating, which the RFP defined as “can 

potentially cause disruption of schedule, increased cost or degradation of 

performance.” RFP at 42. 

 

The protest is denied. 

Lynn H. Gibson 

Acting General Counsel 

 

4

 The RRP defined a low risk rating as “little potential to cause disruption of 

schedule, increased cost or degradation of performance.” RFP at 42.