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ARTICLE · 10 OCTOBER 2025

COFC Decision Highlights Risks In Mentor-Protégé Joint Venture Agreements

On September 18, the Court of Federal Claims (COFC) issued a decision in Multimedia Environmental Compliance Group JV v. United States, denying a bid protest...

United StatesGovernment, Public Sector

On September 18, the Court of Federal Claims (COFC) issued a decision in Multimedia Environmental Compliance Group JV v. United States, denying a bid protest that challenged the Small Business Administration's (SBA's) Office of Hearings and Appeals (OHA) ruling on joint venture eligibility.

The case reinforces SBA's insistence that mentor-protégé joint venture agreements (JVAs) must not only include the required provisions under 13 C.F.R. § 125.8 but also clearly establish that the small business protégé, not the mentor, maintains real and practical control over contract performance.

Background

The dispute arose from a Navy procurement for environmental compliance engineering services, issued in June 2022 as a total small business set-aside. Multimedia Environmental Compliance Group JV (Multimedia), formed under SBA's mentor-protégé program, submitted a proposal. After a competitor, Acacia7 JV, filed a size protest, the SBA Area Office determined that

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