41 U.S.C. § 2106
Reporting information believed to constitute evidence of offense
A person may not file a protest against the award or proposed award of a Federal agency procurement contract alleging a violation of section 2102, 2103, or 2104 of this title, and the Comptroller General may not consider that allegation in deciding a protest, unless the person, no later than 14 days after the person first discovered the possible violation, reported to the Federal agency responsible for the procurement the information that the person believed constitutes evidence of the offense.
Notes of Decisions
Cited in 6
cases (6 in the last 5 years), 2021–2025 · leading case: Insight Pub. Sector, Inc. v. United States (Fed. Cl. 2021).
Insight Pub. Sector, Inc. v. United States (Fed. Cl. 2021). “41 U.S.C. § 2106 . 7 While Plaintiff contends that the 14-day time bar is inapplicable in bid protests brought before the Court of Federal Claims given the statute specifically references protests filed before the “Comptroller General” at the GAO, Pl.”
Insight Pub. Sector, Inc. v. United States (Fed. Cl. 2022). “See 41 U.S.C. § 2106 . When reviewing a contracting officer’s conclusions as to whether an alleged PIA violation impacted an award, “the Court must analyze whether the Agency conducted an adequate investigation consistent with the arbitrary and capricious standard of review.”
Melwood Horticultural Training Ctr., Inc. v. United States (Fed. Cl. 2021). “41 U.S.C. § 2106 . Melwood asserts that it met those requirements by raising its concerns with the Department of Justice in July 2020, and with SourceAmerica on October 15, 2020.”
Advanced Tech. Sys. Co. v. United States (Fed. Cl. 2024). “Thus, the court must consider the meaning of the following language: 9 The parties also raise several other arguments pertaining to the disclosure claims: (1) whether ATSC’s PIA claim is barred by the statute of limitations in 41 U.S.C. § 2106 , (2) whether ATSC’s proprietary…”
Loyal Source Gov't Servs., LLC v. United States (Fed. Cl. 2025). “41 U.S.C. § 2106 . Loyal Source attempted to send its letter to Mr.”
Brandt Dev. v. United States (Fed. Cl. 2025). “at 7–8, 9 (citing the Procurement Integrity Act, 41 U.S.C. § 2106 ). Alternatively, Brandt Development claims the protest was timely under common law rules of “Fraud-Based Discovery” and “equitable tolling.”
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