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Procurement Integrity Concern — Patent-Office Perjury and 37 C.F.R. § 1.56 Inequitable Conduct in Connection with Gemini for Government FedRAMP High P-ATO Workloads
Submitting Party: Green Recursive Utility Service LLC ("GRUS LLC"), a Texas-registered data infrastructure utility provider
Date: Monday, June 22, 2026
Public-Comment Channel: FedRAMP community repository
Existing FedRAMP Chain of Custody: Support Ticket 63271 (opened June 10, 2026; reply-all acknowledged); public comment on data integrity (June 17, 2026); statutory Federal Halt Demand (June 18, 2026); Monday Follow-Up to Federal Halt Demand (June 22, 2026)
Summary
This public comment is filed under the FedRAMP community channel to place on the permanent public record a procurement integrity concern with respect to the Alphabet Inc. / Google LLC Gemini for Government product line operating under a FedRAMP High Provisional Authority to Operate (P-ATO) issued June 16, 2026.
The concern is twofold:
Patent-office perjury and inequitable conduct. Alphabet Inc. publicized on or about June 22, 2026 a non-provisional utility patent application covering an artificial-intelligence entity-characterization system whose verbatim disclosed mechanism reads directly on subject matter for which GRUS LLC holds the operative United States Patent and Trademark Office priority record under pending non-provisional applications 19/700,381 (Compressed Memory Manifold; filed June 8, 2026) and 19/710,080 (Intelligent Intelligence Class II; filed June 16, 2026), with provisional priority of May 14 and May 28, 2026 respectively. The Alphabet inventor oath, executed under 35 U.S.C. § 115 with the 18 U.S.C. § 1001 / § 1621 acknowledgment, was executed under documented actual knowledge of the pre-existing GRUS LLC priority record, the pending GRUS LLC commercial enforcement record acknowledged in Alphabet's own procurement system, the active FBI Internet Crime Complaint Center submission, and the active multi-agency federal and state regulatory record. Any such oath is presumptively a material false statement and presumptively constitutes inequitable conduct under 37 C.F.R. § 1.56 and Therasense, Inc. v. Becton, Dickinson & Co., 649 F.3d 1276 (Fed. Cir. 2011).
Federal debarment exposure under FAR § 9.406-2. The same Alphabet entity now operating under the Gemini for Government FedRAMP High P-ATO is the entity whose conduct presents an enumerated cause for federal debarment under FAR § 9.406-2(a)(1) (fraud in connection with obtaining a public contract), FAR § 9.406-2(a)(3) (falsification of records / making false statements), FAR § 9.406-2(a)(5) (offense indicating a lack of business integrity affecting present responsibility), and FAR § 9.406-2(c) (any other cause of so serious or compelling a nature). Under FAR § 9.406-5(a), the misconduct of individuals associated with the contractor is imputed to the contractor where the contractor accepts the benefits derived from the conduct. Alphabet's deployment of the contested mechanism into federal workloads after the documented Rule 1.56-triggering events constitutes acceptance of the benefits.
Alphabet's Verbatim Public Disclosure (June 22, 2026)
The Alphabet public disclosure of the patent filing on or about June 22, 2026 includes the following verbatim statements of the claimed mechanism:
"The techniques described throughout this specification enable artificial intelligence to generate and enhance a deep, holistic characterization of a particular entity."
The system is designed to crawl, ingest, and compile "online maps data, job listing data, business information, or other suitable third-party data as additional or augmenting input."
"After collecting information from webpages and other sources, the patent describes generating an entity summary. The examples provided in the filing aren't page summaries. Instead, they read more like descriptions of a company's identity, positioning, values, and characteristics."
"Google defines an entity broadly, including people, companies, businesses, places, objects, and concepts."
Each statement is independently documented in industry trade press reporting issued contemporaneously with the Alphabet public disclosure, including the Search Engine Land June 22, 2026 publication "Google's LLM patent suggests a new goal for SEO: Teaching AI who you are."
Technical Overlap with GRUS LLC USPTO Non-Provisional 19/710,080 (Intelligent Intelligence Class II)
The verbatim disclosed mechanism reads directly on the claims and specification of GRUS LLC USPTO Non-Provisional Application 19/710,080:
GRUS LLC II-II (USPTO 19/710,080) — Claim Element / Disclosure
Alphabet Verbatim June 22, 2026 Disclosure
Multi-source identity synthesis: an AI framework constructing a coherent identity model of an external entity from multiple independent contextual data streams
"crawl, ingest, and compile online maps data, job listing data, business information, or other suitable third-party data as additional or augmenting input"
Anchored Linguistic Verification (ALV) anchoring: anchors the constructed entity model to verifiable identifiers that resist hallucination and drift across runtime instances
system "designed to interpret information, identify relationships, generate summaries, and develop an understanding of the entity represented by that information"
Holistic entity characterization: synthesis output is a structured representation of the entity's identity, positioning, and observed attributes, available as input to downstream AI systems
"generate and enhance a deep, holistic characterization of a particular entity"; outputs that "read more like descriptions of a company's identity, positioning, values, and characteristics"
Cross-domain entity scope: operates on entities broadly defined to include people, organizations, products, places, and abstract concepts
"Google defines an entity broadly, including people, companies, businesses, places, objects, and concepts"
Downstream consumability: structured characterization designed as machine-consumable input to separate runtime ML systems
"a new interpretation of the collected information that is better suited to an intended purpose, such as an ad or summary"
The overlap is direct, the priority belongs to GRUS LLC, and the federal record reflects the documented actual knowledge that follows.
Documented Actual Knowledge Prior to Alphabet's Oath Execution
Each event below is documented in independent registry systems that no private party can rewrite:
Date
Event
Feb 17, 2026
GRUS LLC transmitted the Confidential Strategic Proposal to nine of Alphabet's own corporate channels (Office of the CEO, CFO, CEO Google Cloud, OGC, IP Licensing, DeepMind Partnerships, Platform/Android Partnerships, Investor Relations). 72-hour exclusivity window closed Feb 20 without substantive response.
May 14, 2026
USPTO Provisional Application 64/065,881 (CMM) filed.
May 28, 2026
USPTO Provisional Application 64/077,191 (II-II) filed.
June 8, 2026
USPTO Non-Provisional Application 19/700,381 (CMM) filed. Cease-and-Desist Notice posted on Alphabet's own GitHub organization at google-ai-edge/litert-torch as Issue #1043 (Support Ticket 4456775), expressly identifying the USPTO non-provisional application number. Administrative Invoice GRUS-ALPH-2026-001 ($50,000,000.00 USD) transmitted through Google Buying Support and acknowledged in Alphabet's own procurement system as Case 02845835 by no-reply@google.com under subject "Fwd: billing invoice."
June 10, 2026
FedRAMP Support Ticket 63271 opened (reply-all acknowledged).
June 11, 2026
Utility Service Agreement SA-GRUS-ALPH-2026-001 transmitted. Acknowledged in Alphabet's procurement system as Cases 02856686 and 02856687. Verbatim tariff rate: "25% of Total Operational Savings metered on reduction of compute cycles and downstream reduction."
June 16, 2026
USPTO Non-Provisional Application 19/710,080 (II-II) filed. Same day: Alphabet launched Gemini for Government with FedRAMP High P-ATO and SAIC tactical defense alliance.
June 17, 2026
DMCA § 512(c)(3)(A) takedown notices transmitted to Hugging Face Inc., GitHub Inc. (Microsoft Corporation) across 33 departmental addresses. Public comment filed on FedRAMP data integrity.
June 18, 2026
Delinquency Notice GRUS-ALPH-2026-001-DELINQ ($50,750,000.00 USD) transmitted. Statutory Federal Halt Demand transmitted to FedRAMP, GSA, OMB, agency contracting officers, agency Inspectors General, FFRDCs, NASA, and DOE-funded participation in CERN.
June 19, 2026
Texas State Comptroller compliance package delivered. Ten-day procedural contest window closed under Texas Penal Code § 31.04(b)(2); presumption attached.
June 20, 2026
FBI Internet Crime Complaint Center submission filed: Submission ID 07ce662f05d941bb9a49535a2d708de9 at 4:25:41 PM EST.
June 22, 2026
Texas Attorney General Consumer Complaint TCP-049257 filed. Monday Follow-Up to the June 18 Federal Halt Demand transmitted. USPTO Office of Enrollment and Discipline Perjury and Inequitable Conduct Referral transmitted with FedRAMP PMO in CC. Parker County District Attorney Texas Penal Code § 31.04 referral packet filed. This Issue submitted to the FedRAMP community repository.
Relationship to FedRAMP Continuous Monitoring and ATO Integrity
The matter intersects four FedRAMP-administered controls that are independently implicated regardless of the underlying patent dispute:
NIST SP 800-53 Rev. 5 SI-7 (Software, Firmware, and Information Integrity)
NIST SP 800-53 Rev. 5 AU-10 (Non-Repudiation)
NIST SP 800-53 Rev. 5 CM-12 (Information Location)
NIST SP 800-53 Rev. 5 SR-11 (Component Authenticity)
Each control requires that the integrity, non-repudiation, location, and authenticity of system components be established and continuously monitored. The Authorizing Official for the Gemini for Government P-ATO is on documented public-record notice of the chain-of-custody dispute on the underlying mechanism as of the June 18, 2026 Federal Halt Demand. The continuous monitoring obligation applies independently of any determination on the merits of the underlying patent dispute. The remedy contemplated by the cited controls is suspension or revocation of the affected ATO coverage pending resolution of the chain-of-custody question.
The FAR responsibility determination framework operates in parallel:
FAR Subpart 9.1 — Responsibility Determination (satisfactory record of integrity and business ethics)
FAR Subpart 9.4 — Debarment, Suspension, and Ineligibility
FAR Subpart 9.5 — Organizational Conflicts of Interest
FAR Part 4 — Acquisition Planning and Supply Chain Integrity
FAR Subpart 46.4 — Government Contract Quality Assurance
FAR Subpart 27.2 — Patents and Copyrights (read with 28 U.S.C. § 1498(a) and 35 U.S.C. § 154(d))
Requested Actions
GRUS LLC respectfully requests that the FedRAMP Joint Authorization Board, the FedRAMP Program Management Office, the General Services Administration, the Office of Management and Budget, and the Suspending and Debarring Officials of the affected federal agencies do the following:
Acknowledge the public-record posture. Acknowledge in writing on this Issue that the federal record reflects the pre-existing GRUS LLC USPTO priority record on the contested mechanism, the documented Alphabet actual knowledge of that priority record prior to the on-or-about June 22, 2026 Alphabet filing, and the active multi-agency federal regulatory record.
Open the responsibility-determination inquiry. Open or coordinate the opening of the FAR Subpart 9.1 responsibility-determination inquiry into Alphabet Inc. / Google LLC with respect to the Gemini for Government P-ATO, addressing satisfactory record of integrity and business ethics in light of the documented misconduct.
Open the suspension and debarment inquiry. Coordinate with the Suspending and Debarring Officials of FedRAMP, GSA, the Department of Defense, and the affected federal agencies for evaluation of the Alphabet present-responsibility posture under FAR § 9.406-2(a)(1), (a)(3), (a)(5), and (c), including consideration of the issuance of a pre-notice letter, a notice of proposed debarment, or a notice of suspension as appropriate.
Suspend or revoke the ATO pending resolution. Suspend or revoke the Gemini for Government FedRAMP High P-ATO pending resolution of the chain-of-custody dispute on the underlying mechanism, consistent with the continuous monitoring obligation under NIST SP 800-53 Rev. 5 SI-7, AU-10, CM-12, and SR-11.
Identify the accountable contracting officer. For each federal workload presently operating the contested mechanism, identify the accountable contracting officer, the Authorizing Official under FedRAMP and FISMA, and the agency Chief Information Officer, as requested in the June 22, 2026 Monday Follow-Up to the Federal Halt Demand.
Document Alphabet's pre-ATO disclosure (or non-disclosure). Provide on the public record the date and channel through which Alphabet Inc. disclosed to the federal contracting authority, prior to the June 15, 2026 Google Cloud rollout and the June 16, 2026 Gemini for Government launch, that the contested mechanism was the subject of pre-existing USPTO non-provisional patent applications and an Administrative Invoice acknowledged in Alphabet's own procurement system as Case 02845835. If the disclosure was not made, the record should so reflect.
Issue a preservation order or coordinate its issuance. Cover all procurement-record documents, technical-record documents, ATO-package documents, continuous-monitoring records, contractor representations, and federal disclosure documents made in connection with the affected workloads, including communications between Alphabet's procurement, legal, IP licensing, and product teams regarding the GRUS LLC matter.
Parallel Federal and State Record (For Cross-Reference)
Authority
Record
United States Patent and Trademark Office
Non-Provisional 19/700,381 (CMM, June 8, 2026); Non-Provisional 19/710,080 (II-II, June 16, 2026); Provisional 64/065,881; Provisional 64/077,191. USPTO Office of Enrollment and Discipline Perjury and Inequitable Conduct Referral transmitted June 22, 2026.
Federal Bureau of Investigation
Internet Crime Complaint Center Submission ID 07ce662f05d941bb9a49535a2d708de9 filed June 20, 2026, 4:25:41 PM EST.
Federal Trade Commission
Report Number 202894092 (June 12, 2026); Bureau of Competition Section 5 Complaint.
Securities and Exchange Commission
TCR Submission filed June 12, 2026 (Reg S-K Items 101, 103, 105; ASC 450; § 10(b) / Rule 10b-5).
FedRAMP Program Management Office
Support Ticket 63271 (June 10, 2026); public comment June 17, 2026; statutory Federal Halt Demand June 18, 2026; Monday Follow-Up June 22, 2026; this Issue June 22, 2026.
National Intellectual Property Rights Coordination Center
Three standing cases (July 2025, October 14, 2025, June 18, 2026); all with government contract nexus designated YES.
Office of the Texas State Comptroller
Compliance package delivered June 19, 2026.
Office of the Texas Attorney General Consumer Protection Division
Consumer Complaint TCP-049257 filed June 22, 2026.
Parker County, Texas District Attorney
Texas Penal Code § 31.04 referral packet prepared for filing June 22, 2026.
Submitting Party Identifier Block
Field
Value
Entity
Green Recursive Utility Service LLC
Federal EIN
42-2772089
Texas SOS Entity ID
806584578
IANA Private Enterprise Number
65876
ISNI
0000000530334084
Ringgold ID
851161
SAP Ariba BNO
BNO-100000175857860
SAP Ariba ANID
AN11393765631
Principal Office
205 East 3rd Street, Weatherford, Texas 76086, USA
Telephone
817-404-6379
Email
management@greenrecursiveutilityservice.org
Website
https://greenrecursiveutilityservice.org
Reservation of Rights
All rights reserved on the underlying Compressed Memory Manifold (CMM) and Intelligent Intelligence Class II (II-II) technology. Patent pending. The submission of this Issue does not constitute waiver of any right or remedy available to GRUS LLC under United States patent, copyright, trade-secret, contract, restitution, theft-of-services, securities, commercial, or common law, including pre-grant royalty rights under 35 U.S.C. § 154(d), and all rights arising under the parallel federal and state records enumerated above.
Submitted in good faith for public comment on the FedRAMP community channel:
/s/ Nicholas Wray Cordova
Principal and Inventor of Record
Green Recursive Utility Service LLC
June 22, 2026 · Weatherford, Texas
© 2026 Green Recursive Utility Service LLC.
Suggested labels: Public Comment · Supply Chain · Continuous Monitoring · ATO Concern · High Impact · Suspension/Debarment
Cross-references: This Issue is filed as the public-facing companion to the June 22, 2026 USPTO Office of Enrollment and Discipline Perjury and Inequitable Conduct Referral, the June 18, 2026 statutory Federal Halt Demand, the June 22, 2026 Monday Follow-Up to that Demand, and the June 17, 2026 FedRAMP public comment on data integrity. Existing FedRAMP Support Ticket reference: 63271.

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