In Leader Communications, Inc., the comptroller general of the Government Accountability Office (“GAO”) upheld an agency’s award of a contract for business resources and support services that was protested on grounds of an organizational conflict of interest. Leader Communications, the incumbent contractor, protested the award for the work at the Air Force Research Laboratory (“AFRL”) at Kirtland Air Force Base, to CC&G Company (“CC&G”). In its protest, Leader argued that CC&G should be precluded from award because of an organizational conflict of interest due to the fact that one its joint venture partners, Corporate Allocation Services, Inc. (“CAS”), was currently performing acquisition closeout support services (“ACSS”) for AFRL at the same base.

In concluding that no conflict of interest existed, the comptroller general noted that, “[o]nce an agency has given meaningful consideration to potential conflicts of interest, [GAO] will not sustain a protest challenging a determination in this area unless the determination is unreasonable or unsupported by the record.” In this case, the comptroller general adopted AFRL’s conclusion that there was no organizational conflict of interest because the work performed by CAS under the ACSS contract could in no way influence the award of the subject procurement or influence the performance evaluation of the ultimate awardee. Thus, the protest was denied. B-298734, 2006 WL 3525376 (Comp. Gen. Dec. 7, 2006).