BNUMBER:  B-270998
DATE:  May 7, 1996
TITLE:  Coherent, Inc.

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 Matter of:Coherent, Inc.

File:     B-270998

Date:May 7, 1996

Dr. Stephen P. Smith for the protester.
Edward L. Fitzmaurice, Esq., and Capt. Stephen T. Davis, Department of 
the Air Force, for the agency.
Adam Vodraska, Esq., and James A. Spangenberg, Esq., Office of the 
General Counsel, GAO, participated in the preparation of the decision.

DIGEST

Agency properly accepted awardee's certification that its proposed 
laser model complied with the solicitation's commercial item 
requirement, where although the offered product has not been sold, it 
has been offered for sale to the general public.

DECISION

Coherent, Inc. protests the award of a contract to Laser Systems 
Devices, Inc. (LSDI) by the Department of the Air Force under request 
for proposals (RFP) No. F19650-95-R-0106, for a single frequency 
titanium sapphire ring laser.  Coherent contends that the laser model 
proposed by the awardee fails to meet the commercial product 
requirements of the solicitation.

We deny the protest.

The RFP, issued on July 14, 1995, contemplated the award of a firm, 
fixed-price contract to the responsible offeror submitting the low, 
technically acceptable offer.  The RFP specified a brand name, 
Coherent model "899-01 [Ring Laser] with 895 [Solid Etalon Assembly]," 
or equal.  The RFP listed the solicited laser's salient 
characteristics and required offerors proposing an equal product to 
submit descriptive literature and to specify the manufacturer's name 
and model number.  The RFP included the clause found at Defense 
Federal Acquisition Regulation Supplement (DFARS)  sec.  252.211-7012, 
"Certifications-Commercial Items" Alternate I, which provided that 
"[o]ffers received in response to this solicitation that do not offer 
commercial items shall not be considered for award."[1]  Pursuant to 
that clause, offerors were required by the solicitation to certify 
whether the items proposed were commercial items defined by the clause 
as follows:

     "(b)(1) Commercial items means items regularly used in the course 
     of normal business operations for other than Government purposes 
     which:

        (i)  have been sold or licensed to the general public;

        (ii) have not been sold or licensed, but have been offered for 
     sale or license to the general public;

        (iii)Are not yet available in the commercial marketplace, but 
     will be available for commercial delivery in a reasonable period 
     of time;

        (iv) Are described in paragraphs (i), (ii) or (iii) that would 
     require only minor modification in order to meet the requirements 
     of the procuring agency.

      (2) 'Minor modification' means a modification to a commercial 
     item that does not alter the commercial item's function or 
     essential physical characteristics."

The Air Force received proposals from LSDI, Coherent, and a third 
offeror, and determined that all three proposals were technically 
acceptable and within the competitive range.  LSDI certified in its 
proposal that its proposed laser model TS-202 was a commercial product 
under subclause (b)(1)(ii), that is, that the item has "not been sold 
or licensed, but [has] been offered for sale or license to the general 
public."  On September 28, 1995, the Air Force awarded the contract to 
LSDI as the lowest priced, technically acceptable offeror.  

Coherent questions the Air Force's acceptance of LSDI's certification, 
claiming, in essence, that since LSDI's proposed laser model has not 
actually been sold or licensed to the general public, it is not a 
commercial item.  However, actual sale or license to the general 
public is not required for an item to be considered a commercial 
product under the clause, and LSDI has certified, in accordance with 
the clause, that it has not actually sold or licensed its proposed 
laser model to the general public, but has offered the product for 
sale or license to the general public.  
The determination of whether a product is a commercial item is largely 
within the discretion of the contracting agency, and will not be 
disturbed by our Office unless it is shown to be unreasonable.  See 
Komatsu Dresser Co., B-255274, Feb. 16, 1994, 94-1 CPD  para.  119.  The 
protester does not assert that LSDI's proposed laser model was not 
offered for sale or license to the general public, and there is 
nothing in the record indicating that the contracting officer was on 
notice prior to award of facts which would lead to the conclusion that 
the item to be furnished was not a commercial item as defined in the 
solicitation.  Absent such notice, the contracting officer reasonably 
accepted LSDI's certification in making the award.  See Attachmate 
Corp., B-250030.6; B-250030.7, July 30, 1993, 93-2 CPD  para.  63.   

Coherent nevertheless alleges that under FAR  sec.  11.006, the Air Force 
should have requested information from LSDI on the number of sales and 
the length of time its product has been sold in the commercial 
marketplace in evaluating whether LSDI is indeed offering a commercial 
product.[2]  FAR  sec.  11.006 provides that such information "may be 
requested from each offeror" (emphasis added) in evaluating whether an 
offered product is a commercial product.  The Air Force was thus not 
required to request this information from the offerors in the RFP and, 
as discussed above, could rely upon LSDI's certification that it was 
providing a commercial product.  To the extent Coherent disagrees with 
the Air Force's failure to request such information, its protest of 
the alleged solicitation impropriety is untimely filed after the time 
set for receipt of proposals.  Bid Protest Regulations, 4 C.F.R.  sec.  
21.2(a)(1) (1996). 

The protest is denied.

Comptroller General
of the United States

1. This clause was subsequently deleted from the DFARS by Defense 
Acquisition Circular No. 91-9, Nov. 30, 1995, to conform to changes in 
the Federal Acquisition Regulation (FAR) implementing the provisions 
of the Federal Acquisition Streamlining Act of 1994 (FASA) with regard 
to the acquisition of commercial items.

2. After the solicitation was issued, FAR part 11, Acquisition and 
Distribution of Commercial Products, was completely revised by Federal 
Acquisition Circular No. 90-32, Sept. 18, 1995, in response to FASA to 
address the process of describing agency needs; FAR part 12 now 
addresses the acquisition of commercial items and FAR part 10 the 
market research to be conducted by the agency in determining if 
commercial items meet the agency's requirements.