The Court of Federal Claims explained in the recent bid protest Insight Systems Corp. v. United States, Nos. 12-863C and 12-883C (Fed. Cl. May 6, 2013), that it has seen “with disturbing frequency . . . bid protests that find [the Government] straining to defend agency decisions to reject, as purportedly late, proposals submitted by contractors electronically.” The Court noted that “[t]hese cases somewhat painfully illustrate the thorny issues that can arise when the outmoded provisions of the [FAR] governing delivery of electronic proposals – which date back to the last century – are applied to modern computer technology.” Once again, the Court rejected the Government’s strict defense that “late is late,” opting instead for an approach that permits flexibility in light of the mishaps that can occur with electronic submission.