Opinion for the Court filed by Circuit Judge WILLIAMS.
WILLIAMS, Circuit Judge:
In 1998 the Federal Aviation Administration ("FAA") adopted a subordinate office's findings that petitioner Advanced Management Technology, Inc. ("AMTI") had made misrepresentations in a bid proceeding in which AMTI eventually won a multi-million dollar contract. Because of the misrepresentations, the bidding was reopened. But because the FAA believed AMTI had not intended to defraud...
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