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Anuj Vohra

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Anuj Vohra litigates high-stakes disputes on behalf of government contractors in federal and state court, and maintains an active bid protest practice before the U.S. Government Accountability Office and the U.S. Court of Federal Claims. He also assists clients with an array of issues related to contract formation (including subcontracts and teaming agreements), regulatory compliance, internal and government-facing investigations, suspension and debarment, organizational conflicts of interest (“OCIs”), intellectual property and data rights, and the Freedom of Information Act (“FOIA”).

Prior to entering private practice, Anuj spent six years as a Trial Attorney in the U.S. Department of Justice’s Commercial Litigation Branch. At DOJ, he was a member of the Bid Protest Team—which handles the department’s largest and most complex protests—and served as lead counsel in dozens of matters representing the United States in commercial disputes before the U.S. Court of Appeals for the Federal Circuit, the Court of Federal Claims, and the U.S. Court of International Trade.

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Last week, the Federal Circuit heard oral argument in Global K9 Protection Group, LLC v. United States, a bid protest appeal concerning, in part, whether an awardee who chose not to intervene at the outset of the protest should have been allowed to do so after its award was enjoined.Continue Reading Worried Three’s a Crowd? Decline Intervention at Your Own Peril

Congress has not passed funding bills to keep key parts of the government funded for the remainder of Fiscal Year 2026—including the Departments of Defense, State, Treasury, Labor, Health and Human Services, Transportation, Housing and Urban Development, and Homeland Security, as well as independent agencies, the judiciary, and national security and foreign operations functions. As Congress continues to negotiate a deal in advance of the expiration of funds on January 30, parts of the government may still face a short shutdown, given the time needed for both the Senate and the House to consider and approve legislation. In anticipation of that possibility, agencies whose funding is uncertain are preparing for a shutdown; contractors, grant recipients, and companies that work with those agencies should do the same. Our team is ready and available to advise through the shutdown process.Continue Reading Reminders for a Potential Government Shutdown this Weekend

GAO’s key personnel rule is well-known—and often a source of frustration— amongst government contractors.  Proposed key personnel who become “unavailable” prior to contract award—especially where they have accepted employment with a different company—may doom an offeror’s proposal by rendering it noncompliant with solicitation requirements.  But GAO’s recent decision in FYI – For Your Information, Inc., B-423774, B-423774.2 (Dec. 19, 2025) provides some potential relief from that rule. Continue Reading FYI – GAO Finds Key Person “Available” Despite Accepting Employment with a Different Company

Congress has not passed crucial funding bills for the start of Fiscal Year 2026.  If Congress fails to act by September 30, the government may be forced to shut down for lack of funding.  In anticipation of that possibility, agencies government-wide are preparing for a shutdown, and contractors and companies that work with the government should do so as well.  Our team is ready and available to help advise companies through the shutdown process.Continue Reading Common Questions—and Answers—About A Government Shutdown

On August 7, 2025, the FAR Council issued a final rule amending FAR 52.204-7 to clarify that, effective immediately, an offeror’s failure to maintain continuous System for Award Management (SAM) registration between proposal submission and contract award does not render the offeror ineligible for award, so long as the offeror was registered in SAM at the time of proposal submission and is registered at the time of contract award. The final rule should address situations like TLS Joint Venture, LLC, B-422275, Apr. 1, 2024, 2024 CPD ¶ 74, where an offeror’s SAM registration lapsed for a single day between the proposal submission and award dates, and GAO found the offeror ineligible for award.Continue Reading The End of the Continuous SAM Registration Requirement …. Almost

Last week, we wrote that concerns about excessive, unchecked executive branch power resulting from the Supreme Court’s decision in Trump v. CASA—which declared universal/nationwide injunctions likely exceeded district courts’ equitable authority under FRCP 65—felt premature, because there were a number of other levers district courts could pull to deliver the equivalent of nationwide injunctive relief. We discussed how Section 705 of the Administrative Procedure Act (APA) is one such lever. That section authorizes courts to “postpone the effective date” of a challenged agency action pending judicial review utilizing the same four-factor test applicable to requests for injunctive relief.Continue Reading Meet the New Nationwide Injunction. Same as the Old Nationwide Injunction.

On July 11, 2025, the Department of Education issued a new interpretive rule entitled “Clarification of Federal Public Benefits under the Personal Responsibility and Work Opportunity Reconciliation Act.” The Personal Responsibility and Work Opportunity Reconciliation Act (PRWORA) generally limits “eligibility for ‘federal public benefits’ to U.S. citizens, permanent residents, and certain categories of qualified aliens.” The Department concluded that certain postsecondary education programs, “including adult education programs authorized under Title II of the Workforce Innovation and Opportunity Act of 2014, [and] postsecondary career and technical education programs under the Carl D. Perkins Career and Technical Education Act of 2006,” constitute “Federal public benefits under the PRWORA and thus are subject to PRWORA’s citizenship verification requirements.”Continue Reading New Department of Education Interpretive Rule Ends Federal Education Grants for Undocumented Students

The deadlines for filing a GAO protest are short and strictly enforced.  In post-award protests, the general rule is that a company must file its protest within ten days of when the protester knows, or should have known, of its basis of protest.  However, GAO’s regulations provide an exception to this rule for “protests challenging a procurement conducted on the basis of competitive proposals under which a debriefing is requested and, when requested, is required”—in such a situation, “[the] protest shall not be filed before the debriefing date offered to the protester, but shall be filed not later than 10 days after the date on which the debriefing is held.”  4 CFR §21.2(a)(2).Continue Reading GAO Moves the Goalposts: New Post-Debriefing Timeliness Trap for Protesters

A string of GAO protest sustains this spring, most recently in Owl International Inc., d/b/a Global, a 1st Flagship Company, B-423281, B-423281.2, April 25, 2025, demonstrates that the evaluation of professional employee compensation remains a successful post-award protest argument. Continue Reading Recent GAO Decisions Show Professional Employee Compensation Challenges Remain a Successful Protest Argument