TRAX International Corp. v. United States

TRAX challenged the Army’s award of a White Sands Missile Range services contract. It sought to complete the administrative record with three proposal evaluations generated by FAST TRACK, an AI platform. The government maintained that the outputs were not used in the procurement and disputed their inclusion. Supplemental declarations later disclosed that the procurement analyst had sent AI evaluations to members of the evaluation board and the contracting officer. The court ordered all three evaluations added to the record.

Judge Carolyn N. Lerner found that the government’s account was shifting and at times inaccurate. Its declarations omitted that evaluation-board members and the contracting officer had received AI outputs, and passages in one agency evaluation closely matched the AI-generated evaluation. The court explained that inclusion in the administrative record turns on whether material was generated or considered during the decision process, rather than whether it influenced the final evaluation. Invoking RCFC 11 and the duty of candor, the court ordered four DOJ and Army attorneys to jointly explain the omissions, their factual inquiry, and whether inaccuracies were recognized but left uncorrected.