# Washington, DC 20548

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URL: https://www.frixlaw.com/law-library/documents/agency%3Agao%3A28525758732b8ab4

## Record

- **Collection:** Agency decision
- **Document type:** Agency decision

## Text

441 G St. N.W.
Washington, DC 20548

Comptroller General
of the United States
DOCUMENT FOR PUBLIC RELEASE

Decision

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

Matter of:

DLH, LLC

File:

B-424528; B-424528.2; B-424528.3

Date:

August 31, 2026

Holly A. Roth, Esq., Terry L. Elling, Esq, Tanner N. Slaughter, Esq. and Ben R. Smith,
Esq., Holland & Knight LLP, for the protester.
William M. Jack, Esq., and David T. Hickey, Esq., Dickinson Wright, PLLC, for Dynanet
Corporation, the intervenor.
Brandon Dell’Aglio, Esq., and Karyne C. Akhtar, Esq., Department of Health and Human
Services, for the agency.
Christopher Alwood, Esq., and Alexander O. Levine, Esq., Office of the General
Counsel, GAO, participated in the preparation of the decision.
DIGEST
Protest of a sole-source bridge task order for critical information technology services,
placed against a federal supply schedule contract, is denied where the need for the
services was of such unusual urgency that following the federal supply schedule’s
competitive ordering procedures would result in unacceptable delay.
DECISION
DLH, LLC, of Bethesda, Maryland, protests the Department of Health and Human
Services (HHS), National Institutes of Health’s (NIH) issuance of a 3-month task order
on a sole-source basis to Dynanet Corporation, of Elkridge, Maryland, for information
technology (IT) and information security services in support of NIH’s Office of Innovation
and Information Technology (OIIT). DLH contends that the sole-source task order
lacks a legal basis and arises due to a lack of advanced planning by the agency.
We deny the protest.
BACKGROUND
NIH’s OIIT is responsible for providing IT support for more than 3000 employees in
NIH’s Office of Research Services (ORS) and Office of Research Facilities (ORF).

Agency Report (AR), Tab 1.12, Request for Quotations (RFQ) No. C-120673-SB,
Statement of Work (SOW) at 1. 1 This support includes project management, application
development and operations, application hosting services, desktop support, customer
care, network account administration, internet and intranet services, network resource
management, web development, and IT security. Id. As relevant here, OIIT provides
network application hosting, desktop support, and information security for two IT
environments, NIH’s Enterprise Network and its Facilities Network (FACNet). Id. at 2.
Support for NIH’s FACNet includes network and IT security engineering for ORS and
ORF’s industrial control systems. Id.
For more than a year, NIH has been attempting to issue a task order, on a competitive
basis, for IT services to assist OIIT in meeting its mission requirements to provide IT
support to ORS and ORF. Specifically, in May 2025, NIH issued RFQ
No. C-120673-SB to firms holding contracts under the NIH Information Technology
Acquisition and Assessment Center (NITAAC) Chief Information Officer-Solutions and
Partners 3 small business (CIO-SP3 SB) governmentwide acquisition contract (GWAC).
Contracting Officer’s Statement (COS) at 1. The RFQ contemplated the issuance of a
task order to provide application development, network services, end-user support, and
project management services for a 1-year base period and two 1-year option periods.
AR, Tab 1.12, RFQ No. C-120673-SB, SOW at 1, 3. On July 3, 2025, the agency
issued a task order to Dynanet. COS at 1. DLH and another disappointed vendor
protested the issuance of the task order and the agency promptly notified our Office that
it intended to take corrective action by reevaluating quotations and making a new
source selection decision. Emagine IT, Inc., B-423719, Aug. 8, 2025 (unpublished
decision); DLH, LLC, B-423719.2, B-423719.3, Aug. 8, 2025 (unpublished decision).
Our Office dismissed the protests as academic. Id.
The agency reevaluated quotations and, on May 4, 2026, again issued a task order to
Dynanet. COS at 1. DLH and the other disappointed vendor again protested the
issuance of the task order. Emagine IT, Inc., B-423719.4, June 4, 2026 (unpublished
decision); DLH, LLC, B-423719.5, June 4, 2026 (unpublished decision). In response to
these protests, the agency notified our Office that it intended to take corrective action by
cancelling the solicitation, reconsidering NIH’s requirements, and conducting a new
competitive procurement to meet the requirement. Req. for Dismissal, B-423719.5,
May 29, 2026.
DLH served as the incumbent contractor providing these IT services in support of ORS
and ORF. AR, Tab 1.5, DLH Incumbent Contract; see also Protest at 2; Memorandum
of Law (MOL) at 2. DLH’s incumbent task order supporting the instant requirement
expired on May 18. AR, Tab 1.5, DLH incumbent Task Order at 2. On May 19, NIH
executed a sole-source justification (SSJ) to issue a noncompetitive, federal supply
Some documents in the agency report do not contain a uniform set of page numbers.
For clarity, unless otherwise noted, all citations to the record are to the consecutive
numbering of the pages in the Adobe PDF documents provided by the agency.

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schedule (FSS) task order for a 3-month base period and three 1-month option periods.
AR, Tab 1.1, SSJ at 1.
The SSJ cited General Services Acquisition Regulation (GSAR) 538.7104-3(b)(1)(i) as
authority to issue an FSS sole-source order, explaining that the “need is of such
unusual urgency that following the procedures would result in unacceptable delays in
fulfilling that need.” 2 Id. at 2. On May 19, the same day the SSJ was executed, NIH
issued the sole-source task order at issue here to Dynanet. AR, Tab 1.4, Sole-Source
Task Order. The $3.6 million task order covers a 3-month base period with three
1-month option periods. Id. at 2; AR, Tab 1.11, Performance Work Statement at 2. On
May 26, DLH filed the instant protest challenging the sole-source task order. See
Protest. On June 4, DLH filed a supplemental protest after it had reviewed the agency’s
SSJ. See Supp. Protest.
DISCUSSION
The protester raises various challenges to the issuance of the short-term, sole-source
task order to Dynanet. While our decision does not address every argument, we have
reviewed all the arguments and, as explained below, find no merit to DLH’s objections
to the short-term, sole-source contract.
Interested Party
As an initial matter, NIH and the intervenor argue that DLH is not an interested party to
challenge the agency’s decision to issue the task order on a sole-source basis. Based
on the record and facts before us, we find that DLH is an interested party to challenge
the order.
Under the bid protest provisions of the Competition in Contracting Act of 1984 (CICA),
only an interested party may protest a federal procurement. That is, a protester must be
an actual or prospective bidder or offeror whose direct economic interest would be
affected by the award of a contract or the failure to award a contract. 4 C.F.R.
§ 21.0(a)(1). A protester is not an interested party where it would not be eligible to
receive a contract award were its protest to be sustained. See C3.ai, B-421337,
B-421337.2, Feb. 16, 2023, at 4. Determining whether a party is interested involves the
consideration of a variety of factors, including the nature of the issues raised, the benefit
of the relief sought by the protester, and the party’s status in relation to the
HHS adopted the updated version of Federal Acquisition Regulation (FAR) part 8,
issued as part of the Revolutionary Far Overhaul (RFO), through a class deviation.
HHS FAR Class Deviation 2025-09, amend. 1. For clarity in this decision, citations to
each set of regulations will use the abbreviations “FAR” and “RFO” as appropriate.
Under the RFO, when placing an FSS order, agencies are required to follow the
procedures set forth in GSAR subpart 538.71. RFO 8.401(b). Similar procedures had
previously been set forth in FAR subpart 8.4.

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procurement. RELM Wireless Corp., B-405358, Oct. 7, 2011, at 2. Whether a protester
is an interested party is determined by the nature of the issues raised and the direct or
indirect benefit or relief sought. Id.
The agency argues that DLH is not eligible to receive the task order because the order
was issued as a small business set-aside under FSS special item number (SIN) 54151,
and DLH is not a small business that holds an FSS contract with that SIN. Agency Req.
for Dismissal, June 2, 2026; Agency Resp. to Intervenor’s Req. for Dismissal at 1-2.
However, the agency did not explain why, if this protest were to be sustained, it would
be required to procure a replacement bridge task order from a small business under
FSS SIN 54151. 3 Further, the agency did not demonstrate that it would be prohibited
from issuing a task order to DLH to meet this requirement under the procurement
vehicle the agency used in the prior competitive solicitation for this requirement, the
CIO-SP3 SB GWAC. 4 In short, we see no basis to conclude that the agency could not
reprocure the requirement using a different acquisition strategy, and if the agency did
so, that DLH would necessarily be ineligible to receive the task order. 5
The agency does not explain how this non-competitive acquisition qualifies as a small
business set-aside rather than simply a sole-source order to a firm that happens to be a
small business concern. The agency also did not specifically represent that, if the
protest were sustained, it would seek to procure a task order set aside for that SIN.

3

NIH’s CIO-SP3 SB website states that the ordering period for the GWAC runs through
October 29, 2026, with an ordering period of performance through October 2031.
CIO-SP3 SB IT Services/Solutions, NITAAC, https://www.nitaac.nih.gov/gwacs/cio-sp3small-business (last accessed August 19, 2026).
4

In support of its arguments, the agency cites several of our decisions for the principle
that a protester is not an interested party to challenge an FSS procurement if it does not
hold an FSS contract with the required SIN. See, e.g., Agency Resp. to Intervenor’s
Req. for Dismissal at 2 (citing Manhattan Telecommunications Corp., LLC, B-423414,
B-423414.2, June 30, 2025; BAO Systems, LLC, B-421561.13 et al., Apr. 10, 2024).
However, the facts of those protests are distinguishable from the facts here.
Specifically, in both Manhattan Telecommunications and BAO Systems, the agency
conducted a competition to establish a blanket purchasing agreement under an FSS,
instead of, as here, where the agency conducted a sole-source procurement. In both
cases, we found that the protester was not an interested party to challenge the agency’s
source selection decision because it was not eligible for award under the terms of the
relevant competitive solicitation. Manhattan Telecommunications, supra at 5-6; BAO
Systems, supra, at 11. Accordingly, in each of these cases, there were other eligible
vendors that had participated in the competition such that, were the protests sustained,
the protesters would still not be next in line for award. Here, the protest does not
challenge a competitive procurement and there is no next-in-line vendor in place.
Rather, DLH’s protest challenges the agency’s decision to conduct a sole-source
procurement, meaning that a successful protest would necessarily result in the agency
having to use another acquisition strategy to fulfill the requirement. We further note that
(continued...)
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The intervenor also argues that DLH is not an interested party because it does not have
qualified staff available with the necessary personal identity verification (PIV) credentials
to perform the required services without interruption. Intervenor’s Req. for Dismissal
at 2-5. The intervenor bases this argument, in part, on NIH’s SSJ, which stated that
Dynanet was “uniquely positioned” to perform the bridge contract because it “has
technically qualified staff available immediately with the necessary [PIV] credentials” to
access NIH facilities and IT systems. Id. at 3 (quoting AR, Tab 1.1, SSJ at 2). Dynanet
contends that “NIH’s rationale that only Dynanet could meet these specific [bridge
contract] requirements” in the necessary timeframe meant that DLH is not a prospective
offeror eligible to compete for the bridge task order. Id.
In response to the request for dismissal, DLH argues that it can meet the requirements
of the bridge task order separate from its expired incumbent task order. Protester’s
Resp. to Intervenor’s Req. for Dismissal at 6. In this regard, DLH asserts that its
employees--through their work on a separate NIH task order--performed critical portions
of the bridge task order requirements on May 19 and 20 after DLH’s incumbent contract
had expired but before Dynanet began performance on the sole-source task order.
Protester’s Resp. to Intervenor’s Req. for Dismissal at 6. The protester explains that it
is currently performing an IT task order for NIH’s Office of the Director through which it
has qualified IT personnel with access to PIV credentials and NIH systems. Id.; Protest,
Exh. 4a, DLH Task Order.
Without more, we fail to see how the bridge task order requirements are so restrictive
that it would be impossible for DLH--which had been performing the services at issue
before the bridge task order was issued--to meet them. Based on the protester’s
representations regarding its other NIH IT contract, we find that the intervenor has failed
to demonstrate that DLH is incapable of providing qualified staff that can obtain PIV
credentials to access NIH IT systems and facilities. Further, we note that the SSJ did
not rely on the sole-source authority that only one source was capable of performing the
requirement. In this regard, while the agency stated Dynanet was “uniquely positioned
to provide urgent support[,]” we read this within the context of the SSJ as indicating that
Dynanet was best suited to meet the unusually urgent requirement. AR, Tab 1.1, SSJ
at 2. Had this statement been intended as a finding that other vendors could not
perform the sole-source task order’s services, the agency presumably would have said
so and potentially cited the only one responsible source justification for the use of
noncompetitive procedures.
On this record, we find that neither the agency nor the intervenor has demonstrated
that, if the protest were sustained, DLH would not be eligible to receive a bridge task
(...continued)
in BAO Systems, the protest grounds alleging that the agency had unreasonably limited
competition were resolved on the merits and not dismissed based on the protester’s
interested party status. BAO Systems, supra, at 8.

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order for the requirement at issue. Accordingly, we conclude that the protester is an
interested party to protest the sole-source task order to Dynanet.
Timeliness
In its comments and second supplemental protest, the protester argues, for the first
time, that the agency improperly permitted Dynanet access to DLH employees so as to
later justify the sole-source task order to Dynanet. Comments & Second Supp. Protest
at 11-16. In this regard, DLH contends that the agency permitted Dynanet to begin
performance immediately upon the issuance of the May 4 competitive task order,
thereby giving Dynanet access to nonpublic, competitively useful incumbent workforce
and performance information. Id. at 12. DLH asserts that the agency failed to consider
whether such access constituted an impermissible organizational conflict of interest. Id.
at 15; Protester’s Resp. to Agency’s July 7 Req. for Dismissal at 5.
Under our Bid Protest Regulations, protests based on other than solicitation
improprieties must be filed within 10 days of when the protester knew or should have
known their basis. 4 C.F.R. § 21.2(a)(2). Further, our regulations do not contemplate
the piecemeal presentation or development of protest issues; where a protester raises a
broad ground of protest in its initial submission but fails to provide details within its
knowledge until later, so that a further response from the agency would be needed to
adequately review the matter, these later issues will not be considered. 22nd Century
Techs., Inc., B-413210, B-413210.2, Sept. 2, 2016, at 9.
Here, DLH likely was aware of Dynanet’s allegedly improper transition and onboarding
of employees no later than May 11, 2026, when DLH sent an email to the agency
expressing concerns regarding Dynanet’s attempted employee transitions prior to the
expiration of DLH’s incumbent task order. 6 AR, Tab 1.16, DLH Email to NIH, May 11,
2026. However, the record is clear that by May 20, the protester was certainly aware
that Dynanet had transitioned DLH employees, that the agency had issued a stop work
order related to the competitive task order, that Dynanet was still performing the
requirement for the agency, and that “NIH personnel were less than forthcoming about
the contract vehicle that permitted Dynanet’s performance[.]” Protest at 3. Further, the
record demonstrates that by May 26, DLH knew that the agency had issued the

The protester contends that the language of the May 11 email demonstrates DLH was
not aware Dynanet was conducting these transition activities with the agency’s blessing.
Protester’s Resp. to Agency’s July 7 Req. for Dismissal at 3. Curiously, despite
complaining that the agency did not file a copy of the contracting officer’s reply to DLH’s
May 11 email as an exhibit to the agency’s July 7 request for dismissal, DLH also did
not include a copy of the contracting officer’s reply in its response to that dismissal
request. See id. Given our conclusion below that this protest ground is untimely
regardless of what DLH knew on May 11, we need not review the agency’s response to
DLH’s May 11 email to resolve the protest.

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sole-source task order to Dynanet. Id.; Protest, Exh. 3, SAM.gov Posting for
Sole-Source Task Order at 2.
In sum, we find that the protester had all the information it needed to raise these protest
grounds no later than May 26. 7 Accordingly, DLH was required to raise these protest
grounds by June 5. Since DLH failed to raise them until it filed its second supplemental
protest on July 6, we dismiss these protest grounds as untimely.
Sole-Source Task Order
DLH contends that the agency failed to meet the applicable requirements to award a
sole-source task order under GSAR 538.71. Supp. Protest at 9-13; Comments &
Second Supp. Protest at 2-11. In this regard, the protester argues that NIH failed to
satisfy its requirement to obtain competition to the maximum extent practicable before
moving forward with the sole-source order to Dynanet. Comments & Second Supp.
Protest at 2-5.
We will review an agency’s justification for sole-source FSS orders to ensure they are
reasonable and in compliance with applicable statutory and regulatory requirements.
See, e.g., Castro & Co., LLC, B-419366, Jan. 25, 2021, at 4 (reviewing the use of a
limited sources justification under FAR subpart 8.4); XTec, Inc., B-405505, Nov. 8,
2011, at 3; STG, Inc., B-405082, B-405082.2, July 27, 2011, at 2-3. As discussed
below, we find nothing unreasonable in the agency’s determination that issuance of a
short-term, sole-source task order on an urgent basis was justified.
The sole-source task order at issue was placed against Dynanet’s FSS contract relying
on GSAR 538.7104-3. Orders and blanket purchase agreements placed under the FSS
are exempt from the competitive requirements of CICA and its implementing regulations
in FAR part 6. GSAR 538.7104-3; cf. Noble Supply & Logistics, B-417269, Apr. 30,
2019, at 8 (the issuance of BPAs and orders under FAR subpart 8.4 are generally
exempt from the competition requirements of CICA and its implementing regulations).
Nevertheless, the GSAR requires that an ordering activity “justify its action when
awarding on a sole[-]source basis.” GSAR 538.7104-3. For FSS orders that exceed
the simplified acquisition threshold, sole-source justifications “must be made in writing
and include sufficient detail and supporting rationale to support” the statutory exception
relied upon by the agency. GSAR 538.7104-3(b)(2). The GSAR sets forth five statutory
The protester maintains that it was not aware of the full extent of the agency’s
involvement in Dynanet’s allegedly improper transition activities until the agency filed its
report on June 24. Protester’s Resp. to Agency’s July 7 Req. for Dismissal at 5.
However, our decisions have repeatedly concluded that a protester need not await
perfect knowledge before filing a protest. See, e.g., Valkyrie Enters., LLC, B-414516,
June 30, 2017, at 3-4 n.2. Here, as discussed above, we conclude that DLH had all the
information it needed to raise the supplemental protest grounds at issue no later than
May 26.
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exceptions that support the placement of an FSS order on a sole-source basis,
including, as relevant here, when the “need is of such unusual urgency that following
the procedures would result in unacceptable delays in fulfilling that need[.]”
GSAR 538.7104-3(b)(1)(i).
Here, the SSJ cited the “unusual urgency” exception as authority to issue an FSS
sole-source order. AR, Tab 1.1 at 2. The SSJ recited the procurement history and
explained that this “short-term award is needed to ensure continuity of critical services
while [] NIH reconsiders its requirements and prepares for a new competitive solicitation
to be issued.” Id. The SSJ explained that continuity of services is necessary because,
without this specialized support, NIH will be unable to “sustain facilities, research
infrastructure, and specialized cybersecurity functions” including support of biosafety
containment labs and “high-consequence research sites[.]” Id. The SSJ also stated
that any gap in services “poses a direct threat to NIH safety and operations” because
the services support “mission-critical physical security, emergency response, and
campus infrastructure.” Id. The contracting officer determined that the 3-month base
period was meant to cover “the minimum period reasonably necessary to ensure that a
competitive solicitation can be developed and issued[,]” while the option periods were
meant to be a contingency for unanticipated delays. Id.
We see nothing objectionable in NIH’s issuance of a short-term, sole-source order to
Dynanet in light of the agency’s findings that the services were needed immediately and
that conducting a competition would take months. We find the agency’s justification to
be in line with GSAR 538.7104-3(b)(1)(i), which specifically authorizes restricting
competition where, as here, there is an urgent need such that following the FSS
ordering procedures would result in unacceptable delays.
DLH objects to the agency’s justification, arguing that, on May 19 and 20, its employees
performed the requirements at issue though “a separate, active contract vehicle at the
[a]gency’s direction.” 8 Comments & Second Supp. Protest at 4. The protester avers
that, because the agency’s critical short-term needs were being met through these
alternative means, there was no urgent need to issue a sole-source bridge task order to
meet the requirement. Id. However, the protester does not contend that this separate
vehicle (the other NIH task order) had been modified to include the bridge task order
work, or that there was otherwise a contract or task order in place with a scope that
included the services at issue. Therefore, we view DLH’s arguments here not as
challenging the cited urgent basis to issue the sole-source task, but rather as arguing
that the agency should have issued the bridge task order to DLH instead. Such
arguments do not demonstrate that it was unreasonable or contrary to statute or
regulation for the agency to issue the order to Dynanet. See Systems Integration &
The agency disagrees with the protester’s characterization of events, arguing that DLH
was not performing the requirements at issue on May 19 and 20. MOL at 5. Given our
conclusion above, we need not address this factual dispute in order to resolve the
protest.
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Mgmt., Inc., B-402785.2, Aug. 10, 2010, at 3 (that an agency can issue a sole-source
bridge task order on an urgent basis to an incumbent protester does not render the
agency’s decision to issue the order to another vendor unreasonable).
We are also unpersuaded by the protester’s argument that the agency was required to
obtain competition to the maximum extent practicable here. As an initial matter, we
note that the protester does not identify any specific requirement in the GSAR’s ordering
procedures that agencies obtain competition to the maximum extent practicable when
using the unusual urgency basis to issue a sole-source FSS order. To the contrary, the
GSAR’s general requirement to open competitions above the simplified acquisition
threshold to as many FSS contractors as practicable does not apply when “a
justification is executed and approved in accordance with [GSAR] 538.7107-3(b)[.]”
GSAR 538.7103-3(a).
The protester’s only legal basis for this argument derives from two of our Office’s
decisions discussing the sole-source justification requirements of CICA and FAR part 6.
Protest at 7-8; Comments & Supp. Protest at 5-6 (citing WorldWide Language
Resources, Inc.; SOS International Ltd., B-296993 et al., Nov. 14, 2005; Career Sys.
Dev. Corp., B-411346.11 et al., May 18, 2018). 9 However, as noted above, orders and
blanket purchase agreements placed under the FSS are exempt from the competitive
requirements of CICA and its implementing regulations in FAR part 6. 10
GSAR 538.7104-3; cf. Noble Supply & Logistics, supra at 8. Without more, we fail to
see how this argument demonstrates that the agency’s sole-source justification was
unreasonable or not in compliance with the regulatory requirements of
GSAR 538.7104-3
The protester also argues that NIH improperly relied on the unusual urgency basis as a
result of a lack of advanced planning. Protest at 8-10; Comments & Second Supp.
Protest at 6-9. CICA specifically provides that noncompetitive procedures may not be
used as a result of a lack of advanced planning by contracting officials. 41 U.S.C.
§ 3304(e)(5)(A)(i); RFO 6.103(b)(1). While FSS orders are not subject to the specific
competition requirements of CICA and FAR part 6, our Office has recognized that an
Notably, the Career Systems decision cited by the protester concerns a sole-source
justification based on the “only one responsible source available” exception to
competition, not an unusual urgency exception. See Career Sys. Dev. Corp., supra
at 3, 8-10. The protester does not explain how this decision is relevant to the facts
presented here.
9

FAR section 6.301(d), and the corresponding RFO section 6.103(c), generally require
contracting officers to “solicit offers from as many potential sources as is practicable
under the circumstances” when they are not obtaining full and open competition for the
government’s requirements. The applicable GSAR provisions, however, do not include
a similar requirement when an agency issues orders under the FSS on a
noncompetitive basis.
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agency similarly may not utilize non-competitive FSS procedures as a result of a lack of
adequate advance planning. Noble Supply & Logistics, supra at 8 (citing XTec, Inc.,
B-410778.3, Oct. 1, 2015, at 12, n.18). However, we do not consider an immediate
need for services that arises as a result of an agency’s implementation of corrective
action in response to a protest to be the result of a lack of advanced planning. RCG of
N.C., LLC, B-419691, June 24, 2021, at 6-7 (citing Systems Integration & Mgmt., supra
at 3.)
As described above, the record reflects that NIH tried to issue a long-term task order
competitively for the IT support services in support of OIIT. The SSJ explained that the
short-term, sole-source task order is necessary to allow the agency to implement
corrective action in response to the multiple protests received in response to the two
previous competitive awards. AR, Tab 1.1, SSJ at 3. Given that the delays in awarding
the long-term task order are due primarily to the agency’s reasonable implementation of
corrective action, we do not consider the sole-source task order at issue here to be the
result of a lack of advanced planning.
The protest is denied.
Edda Emmanuelli Perez
General Counsel

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Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/agency%3Agao%3A28525758732b8ab4. Public record. Not legal advice.