See STG International, Inc. v. U.S., COFC Nos. 23-47C; 23-175C, May 24, 2023. I have long argued that there is a distinction between offers and proposals. Offers are sets of promises to act or refrain from acting in a specified way, so made as to communicate a willingness to enter into a bargain. Proposals, despite the stupid definition in FAR 2.101, are packages that presumably contain (1) offers and (2) mere information. The COFC protest decision demonstrates that fundamental idea in