CVTEK, LLC
U.S. Government Accountability Office · GAO
Verified May 14, 2026
- Citation
- CVTEK, LLC, B-423943, B-423943.2 (Comp. Gen. Feb. 12, 2026)
- Decided
- February 12, 2026
Summary
CVTEK, LLC protested the Department of Homeland Security, U.S. Citizenship and Immigration Services' issuance of an information technology support services task order to Spatial Front, Inc. In its supplemental protest, CVTEK's counsel filed citations to GAO bid-protest decisions that either did not exist or did not stand for the propositions asserted. After GAO flagged the irregularities, one of CVTEK's attorneys (from McDonald Hopkins LLC) confirmed he had used Westlaw's CoCounsel generative AI tool to prepare the brief and acknowledged that some of the citations the tool produced were erroneous. Counsel apologized, took responsibility, and represented that the firm had implemented new protocols requiring manual verification of all case citations.
- AI tool:
- Westlaw CoCounsel
What sanction did the court impose?
GAO denied the protest on the merits. Because it denied the protest, GAO declined to exercise its authority to impose sanctions for the non-existent citations; it documented counsel's conduct in the public decision and advised that future filings containing non-existent citations may result in sanctions, accepting counsel's representation that future filings would be manually verified.
Why does CVTEK, LLC matter for law firms using AI?
CVTEK is the rare AI-hallucination case that surfaces outside Article III courts. The Government Accountability Office, sitting as the bid-protest forum that decides billions of dollars in federal procurement disputes annually, applies its own procedural rules and remedies; here it chose to deny the protest and document counsel’s conduct rather than impose sanctions or refer for discipline. For a managing partner at a federal contracts boutique, the lesson is that “we used Westlaw, not ChatGPT” remains no defense: a vendor-branded legal-research AI produced fabricated GAO citations that survived counsel’s review, and the embarrassment was published in a permanent decision that opposing counsel will cite for years.
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.