The Dalton Gang, Inc.; All Points Logistics, Inc.

DOCUMENT FOR PUBLIC RELEASE
The decision issued on the date below was subject to a GAO Protective Order. This redacted version has been approved for public release.

Decision

Matter of:  The Dalton Gang, Inc.; All Points Logistics, Inc.

File:  B-412382.5; B-412382.6; B-412382.8

Date:  March 1, 2017

DIGEST

1.  Protests that the agency failed to consider vendors’ blanket assurances that personnel provided under a blanket purchase agreement would meet the agency’s preferred education and years of experience are denied, where the solicitation advised that statements committing to meet the requirement were insufficient.

2.  Protest that the agency improperly assigned a weakness for a proposed key person is denied, where the agency reasonably determined that the resume of the proposed individual did not demonstrate experience appropriate for the position.

3.  Protest that the agency failed to follow the solicitation’s evaluation criteria with respect to evaluating the past performance of proposed subcontractors is denied, where the protester failed to demonstrate that it was prejudiced by the agency’s action.

The Dalton Gang, Inc. (Dalton), of Warrenton, Virginia, and All Points Logistics, Inc. (All Points), of Merritt Island, Florida, protest the establishment of a blanket purchase agreement (BPA) with New Directions Technology, Inc. (NDTI), under request for quotations (RFQ) No. NNK15537243R, issued by the National Aeronautics and Space Administration (NASA), for information technology (IT) support services.  Dalton and All Points challenge the evaluation of their and the awardee’s quotations, and the agency’s selection decision.

We deny the protests.

BACKGROUND

The RFQ was issued on April 9, 2015, to 12 service-disabled veteran-owned small business concerns that hold General Services Administration (GSA) Federal Supply Schedule (FSS) contracts, under the FSS procedures of Federal Acquisition Regulation (FAR) subpart 8.4.  RFQ at 80; Agency Report (AR), Tab 42, Basis of Award Document, at 439.[1]  The RFQ sought quotations to provide support to NASA’s IT Directorate at Kennedy Space Center in five areas identified in the performance work statement (PWS):  engineering services, software services, program/project management, IT security services, and program analysts/management analysts support.  RFQ, PWS, at 91-92.  The RFQ anticipated the establishment of a BPA under the vendor’s GSA FSS contract with a maximum order value of $40 million, and a 5-year performance period consisting of a base period and four 1‑year options.  RFQ at 72. 

The RFQ advised that a BPA would be established with the vendor that offers the best value considering (in descending order of importance):  (1) special features of the services required for effective program performance, (2) past performance, and (3) price.  Id. at 80.  When combined, the special features and past performance factors were considered more important than price.  Id.  The special features factor consisted of two subfactors:  technical capability, and management approach and plans.  Id. at 72-73. 

As relevant here, under the management approach and plans subfactor, the RFQ required vendors to complete a labor resource plan which included the agency’s preferred position descriptions/titles and estimated labor hours.  Id. at 74, 109.  For each preferred position description/title, the RFQ provided preferred experience, education, and associated skills/disciplines.  Id. at 75-77.  The RFQ required vendors to propose and map labor categories from their FSS contracts to the preferred position descriptions/titles, and provide the number of hours under each position to be performed by the prime contractor versus any subcontractors.  Id. at 74, 109.  Vendors were advised that “[s]imply restating the requirement, stating the [vendor] will meet the government’s requirement, or stating it will hire incumbent personnel to meet the government’s requirement is not adequate.  In addition, [vendors] shall not deviate from their existing GSA Schedule positions.”  Id. at 74.  The RFQ stated that vendors’ labor resource plans would be evaluated to determine the fidelity of the proposed equivalent labor resources from the vendors’ GSA schedules to the government’s preferred education and experience for each position; any variance between the preferred education and experience and the vendor’s proposed GSA schedule positions would be evaluated and assessed for overall risk to performance.  Id. at 83.

Also under the management approach and plans subfactor, the RFQ required vendors to provide resumes to fill two key personnel positions:  managing director and IT privacy expert.  RFQ at 74.  The RFQ stated that the resumes would be evaluated to verify that a specific person has committed to work on the proposed BPA and that the person possessed adequate relevant experience and education.  Id. at 83.  With respect to the IT privacy expert position, the RFQ included the following:

Title	Experience	Education	Skills/Disciplines
IT Privacy Expert	10+ years engineering experience	Technical Bachelor’s degree required, Master’s degree desired	Functioning independently as the subject matter expert in the field of Privacy Management.  Ability to review IT system and IT application’s Privacy and CUI [Controlled Unclassified Information] assessments to ensure completeness and compliance with federal and Agency regulations and support any [Kennedy Space] Center data breach response team activities.  Thorough knowledge of the Federal Privacy, Sensitive But Unclassified (SBU), and CUI regulation, Office of Management and Budget memos pertaining to privacy information protection, NASA Privacy, SBU/CUI Policies, with special focus on privacy information collection and compliance.

See RFQ at 77.

Under the past performance factor, the RFQ stated that the past performance of the prime contractor would be evaluated “as well as any proposed subcontractors whose subcontracts will be valued at or above $2M in any year of the period of performance.”  Id. at 84 (emphasis added).  The RFQ further stated that the past performance information provided “should address the past performance of both the prime as well as any proposed subcontractors whose subcontracts will be valued at or above $2M per year.”  Id. (emphasis added).

NASA received quotations from 11 vendors.[2]  AR, Tab 42, Basis of Award Document, at 439.  Dalton, All Points, and NDTI received the following ratings:

	All Points	NDTI	Dalton
Special Features	Good 2 Strengths 2 Weaknesses	Good 1 Strength 1 Weakness	Good 3 Strengths 1 Weakness
Past Performance (Confidence Level)	Very High	Very High	High
Price	$29,591,938	$30,226,031	$31,125,499

AR, Tab 41, Presentation to Selection Official, at 436.

Under the special features factor, the evaluation team compared the labor categories in vendors’ GSA schedules that were identified in vendors’ labor resource plans with the preferred number of years of experience, education, and skills/disciplines identified in the RFQ.  See AR, Tab 37, Dalton Labor Resource Plan Evaluation; Tab 33, NDTI Labor Resource Plan Evaluation; AR (All Points), Tab 33, All Points Labor Resource Plan Evaluation.  The evaluation team found that Dalton,  All Points, and NDTI each proposed some labor categories that did not meet NASA’s preferred characteristics, thus resulting in what the evaluation team termed negative variances.[3]  Id.

For example, Dalton mapped its disaster recovery specialist-principal labor category from its GSA schedule to NASA’s project manager 2 preferred position.  AR, Tab 23, Dalton’s Proposed Labor Resource Plan.  The evaluation team concluded that Dalton’s proposed disaster recovery specialist-principal category did not mention the preferred skills/disciplines for project management of large, complex projects or configuration management.  AR, Tab 36, Dalton Special Features Findings, at 410.  The evaluation team noted that the labor category exceeded the preferred years of experience and education--a positive variance--but concluded that the years of experience were not in the relevant skills/disciplines necessary to perform the functions of a project manager 2.  Id.  In total, the evaluation team found that 17 of the 22 labor categories that Dalton proposed from its GSA schedule had a negative variance from NASA’s preferred experience, education, or skills/disciplines, and Dalton was assigned a weakness on this basis.  Id.

Similarly, the evaluation team found that 11 of All Points’s proposed labor categories had negative variances, and assigned a weakness to All Points’s quotation on this basis.  AR (All Points), Tab 32, All Points Special Features Findings, at 473.  The evaluation team also found that 6 of NDTI’s proposed labor categories had negative variances, and assigned a weakness on this basis.  AR, Tab 32, NDTI Special Features Findings, at 392. 

With respect to key personnel, the evaluation team assigned All Points a weakness because its proposed IT privacy expert did not sufficiently meet the preferred skills/disciplines.  AR (All Points), Tab 32, All Points Special Features Findings, at 472.  In particular, the evaluation team noted that the candidate had only 5 years of relevant experience in the field of privacy management, and did not demonstrate the preferred 10 years of experience with the skills/disciplines necessary to effectively perform the duties of the position.  Id.  The evaluation team concluded that, overall, the candidate’s resume did not demonstrate the preferred experience and skills/disciplines in privacy management, which increases the risk of unsuccessful performance.  Id.

Under the past performance factor, the evaluation team considered the past performance of primes and subcontractors.  Dalton proposed to perform 51 percent of the work itself, and stated that the value of its subcontractor’s work exceeded $2 million.  AR, Tab 22, Dalton’s Proposal, at 260, 279.  The evaluation team found that Dalton’s recent and relevant past performance covered four of the five PWS areas the firm proposed to perform, and that its subcontractor’s past performance covered all five PWS areas.  AR, Tab 38, Dalton Past Performance Evaluation, at 421.  The evaluation team concluded that there was a high level of confidence that Dalton would successfully perform the requirement.  Id.

All Points proposed to perform almost 71 percent of the work itself, but did not explicitly advise NASA about whether or not its proposed subcontractor was expected to perform at least $2 million of the work in any year.[4]  See AR (All Points), Tab 19, All Points’s Proposal, at 254.  The evaluation team nonetheless evaluated the past performance of All Points’s proposed subcontractor.  AR (All Points), Tab 34, All Points Past Performance Evaluation, at 483-484.  The evaluation team found that All Points’s past performance contracts cumulatively covered all five areas of the PWS, and its subcontractor’s past performance contracts covered four of the five PWS areas.  Id. at 484.  The evaluation team concluded that there was a very high level of confidence that All Points would successfully perform the requirement.  Id.

NDTI proposed to perform roughly [Deleted] percent of the work itself, with its two proposed subcontractors to perform the remaining [Deleted] percent.  See AR, Tab 18, NDTI Labor Resource Plan, at 200.  The evaluation team noted that NDTI did not identify how many hours each subcontractor was proposed to work, and evaluated the past performance of both subcontractors.[5]  AR, Tab 34, NDTI Past Performance Evaluation, at 402.  As relevant here, the evaluation team found that NDTI’s past performance contract covered four of the PWS areas.  Id.  The evaluation team noted that the firm’s quotation mentioned experience in all five PWS areas, however, the evaluation team concluded that there were not enough details to demonstrate experience in IT security services support.  Id.  The evaluation team found that NDTI’s two subcontractors had relevant experience in the PWS areas in which they would perform.  Id.  NDTI’s past performance received four exceptional ratings and one excellent rating in the past performance information retrieval system.  Based on the information provided, the evaluation team concluded that there was a very high confidence that NDTI would successfully perform the requirement.  Id.

The selection official received a briefing from the evaluation team, and reviewed the team’s findings and ratings.  AR, Tab 42, Basis of Award Document, at 439, 453.  Overall, the selection official concurred with the findings and adjectival ratings of the evaluation team.  Id. at 453.  However, the selection official disagreed with the evaluation team with respect to NDTI’s past performance.  Id. at 454 n.1.  The selection official found that NDTI’s past performance demonstrated relevant experience in the PWS area of IT security services support, and therefore in his view, the vendor demonstrated past performance in all five PWS areas.  Id.

In making his selection decision, the selection official first eliminated from consideration the four quotations that received a rating of less than good under the special features factor.  Id. at 453-454.  Next, the selection official looked at the past performance of the seven vendors that received a good rating under the special features factor.  Id. at 454.  As relevant here, the selection official considered Dalton’s quotation, noting that:  Dalton’s price was somewhat higher than the prices of other, more highly-rated vendors; Dalton’s past performance involved contracts that were significantly smaller than the IT support services contract; and Dalton proposed labor categories from its GSA schedule that were not comparable to NASA’s preferred positions for several high labor-hour, higher-level positions.  Id. at 455.  Based on these issues, the selection official eliminated Dalton from further consideration.[6]  Id.

Of the four remaining quotations, the selection official noted that All Points and NDTI offered the lowest prices.  AR, Tab 42, Basis of Award Document, at 455.  The selection official acknowledged All Points’s lower price, but concluded that the lower price did not outweigh the risks that All Points’s quotation presented.  Id.  In this regard, the selection official found the weakness posed by the individual All Points proposed as the IT privacy expert to be a discriminator, and concluded the strength All Points’s quotation received for its proposed training plan did not compensate for the weakness.  Id. at 456.  Additionally, the selection official concluded that All Points’s quotation had a greater number of negative variances with respect to NASA’s preferred experience, education, and skills/disciplines than NDTI’s quotation, and that All Points’s negative variances were in positions that represented a greater number of labor hours and therefore would have a greater impact on contract performance.  Id.  Accordingly, the selection official determined that NDTI’s quotation represented the best value to the government.  Id. at 457.

After receiving notification of the award to NDTI, Dalton and All Points protested to our Office.

DISCUSSION

Dalton and All Points raise multiple challenges to NASA’s evaluation of their quotations.  For example, the protesters argue that NASA improperly evaluated and assigned weaknesses to their labor resource plans under the special features factor.  Additionally, All Points challenges the agency’s assignment of a weakness to its quotation for its proposed IT privacy expert.  All Points also argues that NASA failed to evaluate the past performance of the awardee’s subcontractors in accordance with the terms of the solicitation.  We address several of the protesters’ arguments below.  In reaching our decision, we have considered all of the protesters’ arguments and conclude that none provide a basis to sustain the protests.

Evaluation of Labor Resource Plans

Dalton and All Points argue that NASA improperly evaluated their labor resource plans under the special features factor when the agency assigned weaknesses for failure to propose GSA schedule contract labor categories that met the RFQ’s preferred education and experience minimums.  Specifically, the protesters argue that the agency failed to properly consider their commitments to provide staff that met NASA’s preferred levels of education and experience, even where the minimum levels of education and experience listed in their GSA schedules were lower.  Dalton’s Comments at 4; All Points’s Comments at 5. 

Where, as here, an agency issues an RFQ to FSS vendors under FAR subpart 8.4 and conducts a competition for the issuance of an order or establishment of a BPA, we will review the record to ensure that the agency’s evaluation was reasonable and consistent with the terms of the solicitation and applicable procurement laws and regulations.  Digital Solutions, Inc., B-402067, Jan. 12, 2010, 2010 CPD ¶ 26 at 3-4; DEI Consulting, B-401258, July 13, 2009, 2009 CPD ¶ 151 at 2.  In reviewing a protest challenging an agency’s technical evaluation, our Office will not reevaluate the quotations; rather, we will examine the record to determine whether the agency’s evaluation conclusions were reasonable and consistent with the terms of the solicitation and applicable procurement laws and regulations.  OPTIMUS Corp., B-400777, Jan. 26, 2009, 2009 CPD ¶ 33 at 4.  A protester’s disagreement with the agency’s judgment, without more, does not establish that an evaluation was unreasonable.  DEI Consulting, supra.

The record shows that the agency’s actions were reasonable.  As set forth above, the RFQ required vendors to complete a labor resource plan which included the agency’s preferred position descriptions/titles along with the preferred experience, education, and associated skills/disciplines.  The RFQ required vendors to propose and map labor categories from their GSA schedule contracts to these preferred position descriptions/titles, and stated that vendors would be evaluated to determine the fidelity of the proposed equivalent labor resources to the government’s preferred education and experience for each position.  RFQ at 74.  In this regard, the RFQ advised vendors that “stating the [vendor] will meet the government’s requirement . . . is not adequate.”  Id.  The RFQ further advised vendors against deviating from their existing GSA schedule positions.  Id.

In accordance with the RFQ, the evaluation team compared the labor categories in vendors’ GSA schedules that were identified in vendors’ labor resource plans with the preferred number of years of experience, education, and skills/disciplines identified in the RFQ.  See AR, Tab 37, Dalton Labor Resource Plan Evaluation; Tab 33, NDTI Labor Resource Plan Evaluation; AR (All Points), Tab 33, All Points Labor Resource Plan Evaluation.  The evaluation team found that All Points and Dalton proposed some labor categories that did not meet NASA’s preferred education and experience minimums.  The agency did not find sufficient the protesters’ blanket commitments to provide individuals with greater levels of education and/or years of experience than indicated by their GSA schedule labor categories.  We find the agency’s evaluation is consistent with the RFQ language, and does not provide a basis for sustaining the protests.[7]

Dalton also argues that it was unreasonable for NASA to evaluate its GSA schedule positions against the skills/disciplines listed in the RFQ for each of the government’s preferred positions.  Dalton’s Comments at 4.  Dalton contends that the RFQ only stated that education and experience would be evaluated, and that evaluating whether Dalton’s labor category descriptions match the skills/disciplines listed in the RFQ is not the same as considering education and experience.  Id.

NASA states that it included a description of the skills/disciplines related to each of its preferred positions in the RFQ because consideration of the skills/disciplines was necessary, together with the preferred years of experience and education, to determine whether a vendor was capable of performing the work in the PWS using its proposed position.  Contracting Officer’s Statement at 13.  The agency states that some of the GSA schedule labor categories identified by Dalton increased the risk that candidates for the positions would not have the ability to perform the government’s requirements.  Id. at 16.  For example, Dalton mapped its disaster recovery specialist position to NASA’s project manager 1 position.  Id.  The agency explains that, although the disaster recovery specialist position is listed as requiring more years of experience, the skills/disciplines have nothing in common.  Id.; AR, Tab 36, Dalton Special Features Findings, at 410.  In particular, the disaster recovery specialist position does not indicate any experience with project management or configuration management, but instead discusses developing emergency management and business recovery plans and strategies, and other activities related to disaster recovery.  Id. at 16-17; AR, Tab 36, Dalton Special Features Findings, at 410.

Agencies are required to evaluate quotations based solely on the factors identified in the solicitation, and must adequately document the bases for their evaluation conclusions.  IBM Global Bus. Serv. - U.S. Fed., B-409029, B-409029.2, Jan. 27, 2014, 2014 CPD ¶ 43 at 4.  In evaluating quotations, an agency properly may take into account specific, albeit not expressly identified, matters that are logically encompassed by, or related to, the stated evaluation criteria.  Complete Packaging & Shipping Supplies, Inc., B‑412392 et al., Feb. 1, 2016, 2016 CPD ¶ 28 at 6.

The record shows that the agency’s approach of comparing vendors’ GSA schedule position descriptions with the skills/disciplines listed in the RFQ is logically encompassed by the stated evaluation criteria.  As noted by Dalton, the RFQ stated that vendors’ labor resource plans would be evaluated to determine the fidelity of the proposed equivalent labor resources to the government’s preferred education and experience for each position.  RFQ at 83.  The RFQ included a table of NASA’s preferred education and experience that included a column listing the skills/disciplines associated with each position.  Id. at 75-77.  We agree with the agency that the skills/disciplines associated with each of NASA’s preferred positions are logically related to an assessment of whether the type of experience for vendors’ GSA schedule labor categories is consistent with the type required to perform successfully under the BPA.  Accordingly, we find no basis to sustain this protest ground.

Dalton also contends that its quotation should have been rated as very good rather than good under the special features factor, where its quotation was assessed as having 3 strengths and 1 weakness.  Dalton’s Comments at 6.  We need not address Dalton’s objection to the rating assigned to its quotation because the record shows that, although the selection official grouped the quotations according to adjectival ratings, he based his comparison of quotations upon the evaluated attributes in each quotation and not the assigned adjectival ratings.  In this regard, ratings, be they numerical, color, or adjectival, are merely a guide to, and not a substitute for, intelligent decision making in the procurement process.  InfoZen, Inc., B-408234 et al., July 23, 2013, 2013 CPD ¶ 211 at 8.  The germane consideration is whether the record shows that the agency fully considered the actual qualitative differences in vendors’ quotations.  Id.  Here, the record demonstrates that the selection official considered the qualitative differences in making his selection decision.  See, e.g., AR, Tab 42, Basis of Award Document, at 455.  For example, before eliminating Dalton from consideration for the BPA, the selection official considered:  Dalton’s higher price; Dalton’s significantly smaller contracts for past performance; and Dalton’s proposed labor categories that were not comparable to NASA’s preferred positions for several high labor-hour, higher-level positions.  Id.

Key Personnel

All Points argues that NASA improperly assigned its quotation a weakness for its proposed IT privacy expert.  All Points’s protest at 13-14.  All Points contends that its candidate exceeded the agency’s requirement for the position because the individual obtained a bachelor’s degree in computer science and a master’s degree in IT management, and earned other professional certifications that the protester asserts are germane to the position.  All Points’s Comments at 11.  All Points also contends that its candidate “easily” exceeded the agency’s preference for more than 10 years of engineering experience because his engineering experience was in the areas of software, security, and related managerial duties.  Id. at 11-12.  All Points also argues that its candidate’s resume demonstrated significant experience in the area of information assurance and provided information systems security and related experience.  Id. at 12.  For example, All Points states that its candidate was responsible for software engineering efforts that permitted an agency to securely screen detainees in Iraq.  Id.  Finally, All Points argues that NASA unreasonably evaluated its proposed IT privacy expert against the skills/disciplines in the RFQ, even though the skills/disciplines were not labeled as “preferred.”  Id. at 11, 13.

NASA states that it evaluated the resume consistent with the RFQ.  In response to the protester’s argument, the agency explains that the information contained in the resume of All Points’s proposed IT privacy expert focused on work unrelated to the skills necessary for an IT privacy expert, such as database creation and software installation.  AR Legal Memorandum at 9.  Additionally, the agency states that neither the candidate’s work involving secure screening nor other information in his resume demonstrates experience with IT privacy.  Id.

The evaluation of quotations, like the evaluation of proposals, is within the discretion of the procuring agency, since it is responsible for defining its needs and the best method of accommodating them.  IBM U.S. Fed., a division of IBM Corp.; Presidio Networked Solutions, Inc., B-409806 et al., Aug. 15, 2014, 2014 CPD ¶ 241 at 10.  Where, as here, an agency issues an RFQ to FSS contractors under FAR subpart 8.4 and conducts a competition, we will review the record to ensure that the agency’s evaluation is reasonable and consistent with the terms of the solicitation.  Tetra Tech AMT, B-411934.2, B-411934.3, May 17, 2016, 2016 CPD ¶ 136 at 7.  A protester’s disagreement with the agency’s judgment, without more, does not establish that an evaluation was unreasonable.  DEI Consulting, supra.

The record shows that the agency reasonably evaluated All Points’s proposed IT privacy expert.  As indicated above, the RFQ advised offerors that the agency would evaluate the resumes of proposed key personnel to verify that the candidate possessed adequate relevant experience and education.  RFQ at 83.  The skills/disciplines related to the IT privacy expert position stated that the individual:  must function independently as the subject matter expert in the field of privacy management; should have a thorough knowledge of regulations pertaining to sensitive but unclassified and controlled unclassified information; and should have a special focus on privacy information collection and compliance.  Id. at 77.  The evaluation team noted that All Points’s candidate has only five years of relevant experiences in the field of privacy management, and does not demonstrate the preferred 10 years of experience with the skills/disciplines necessary to effectively perform the duties of the position.  AR (All Points), Tab 32, All Points Special Features Findings, at 472.  Further, the evaluation team stated that there was no mention of privacy or controlled unclassified information assessments in any of the cited experience.  Id.

All Points does not argue that its candidate’s resume addresses all of these issues, but rather disagrees with the agency’s view that information assurance and security screening do not demonstrate experience with IT privacy issues.  As discussed above, with regard to All Points’s argument challenging the agency’s use of the RFQ’s skills/disciplines to assess whether a candidate meets the requirements for an IT privacy expert, we conclude that utilization of skills/disciplines is logically related to the issue of experience.  Therefore, this protest ground is denied.

Past Performance

All Points also argues that NASA failed to evaluate the awardee’s quotation under the past performance factor in accordance with the terms of the solicitation.  All Points’s Supp. Protest at 3-8.  All Points contends that the agency improperly evaluated the past performance of NDTI’s two subcontractors because the awardee’s proposal does not demonstrate that the subcontractors will perform at least $2 million per year.  Id. at 5-6.  All Points further contends that the high rating given to one subcontractor’s past performance was not supported by the record.  Id. at 7-8.

We need not reach All Points’s contentions because, even if our Office were to find them meritorious, the record does not support a finding that the protester was prejudiced by the alleged evaluation errors.  Prejudice is an essential element of every viable protest, and we will not sustain a protest where it is clear from the record that a protester suffered no prejudice as a result of an agency evaluation error.  Consummate Computer Consultants Sys., LLC, B-410566.2, June 8, 2015, 2015 CPD ¶ 176 at 6 n.6.

All Points has not demonstrated that NDTI’s past performance confidence rating would have changed if the evaluation team had not evaluated its subcontractors’ past performance.  In this regard, the record shows that the selection official concluded that NDTI demonstrated past performance in all five of the PWS areas, and received primarily exceptional ratings in the past performance information retrieval system.  See AR, Tab 42, Basis of Award Document, at 454 n.1; Tab 34, NDTI Past Performance Evaluation, at 402.  Accordingly, we find no basis to conclude that All Points was prejudiced by any errors in the evaluation of past performance.

The protests are denied.

Susan A. Poling
General Counsel

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