[Request for Review of Navy Denial of Claim for Consulting Fees]

A firm requested review of the Navy's denial of payment for consultation fees in connection with a solicitation for a signage system, contending that the Navy used its services to develop bid specifications under false pretenses by orally agreeing to award it the contract. GAO held that the: (1) Navy drafted its specifications based on the claimant's advice; (2) Navy did receive a benefit; and (3) claimant should be reimbursed on a quantum valebant basis for the services it rendered. Accordingly, the claim was allowed.