Matter of Adapt Forward, LLC
U.S. Government Accountability Office · GAO
Verified May 14, 2026
- Citation
- Matter of Adapt Forward, LLC, B-424006 (Comp. Gen. Feb. 18, 2026)
- Decided
- February 18, 2026
Summary
Adapt Forward, LLC, the incumbent contractor, protested a Navy task-order award to 3ReSen, LLC under solicitation N6523624R30260004 supporting the Naval Information Warfare Center Atlantic Cybersecurity Service Provider team. While reviewing the protest, a GAO attorney could not locate the cases cited by the protester and requested updated citations. None of the original citations correctly identified both the B-number and decision date, and one contained an inaccurate B-number. The protester supplied corrected citations, but none of the three decisions actually supported the proposition for which they were offered. GAO denied the protest on the merits and used a separate passage to warn that the citation of non-existent or inapposite decisions, of a kind that might have been generated by artificial intelligence, may implicate applicable rules of professional conduct and may result in referral to bar associations or other disciplinary bodies.
- AI tool:
- Implied (AI/LLM-generated citations)
What sanction did the court impose?
Protest denied on the merits. No monetary sanction or formal referral was imposed in this decision, but GAO issued an explicit warning that future citation of non-existent authority by counsel appearing before GAO may result in referral to bar associations or other disciplinary bodies.
Why does Matter of Adapt Forward, LLC matter for law firms using AI?
Adapt Forward is a procurement-side companion to the federal-court AI sanctions wave, not an attorney-discipline order. GAO denied the protest on the merits, but used the decision to put the bid-protest bar on notice: when GAO staff cannot find the cases counsel cited, and corrected citations still fail to support the propositions advanced, GAO will treat that as a hallmark of unverified AI-generated drafting and may refer counsel to bar disciplinary bodies in future matters. For a managing partner whose firm handles federal procurement work, the operational takeaway is that the verification standard at GAO is now functionally identical to the standard federal district judges have been imposing under Rule 11: a real attorney must read every cited case before filing.
Sources
Primary sources
Further reading
Source PDF is a Westlaw printout mirrored from the Damien Charlotin hallucination database. We are working to add the underlying court docket (PACER, CourtListener, or court website) as a second source.