Apex Support Services, Inc.

A firm protested the bonding requirements in a General Services Administration (GSA) solicitation for planning and estimating services, contending that the bonding requirements unduly restricted competition. GAO held that GSA failed to demonstrate that it reasonably determined that bonding requirements were necessary to protect the government's interest. Accordingly, the protest was sustained, and GAO recommended that GSA (1) amend the solicitation to delete the bonding requirements and solicit another round of offers, and (2) reimburse the protester the costs of filing and pursuing the protest.