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n. In the attempt to ascertain the outward manifestation of intention expressed by the parties, it is often helpful to consider the general usage or custom prevailing in a given market. See 5 Samuel Williston, A Treatise on the Law of Contracts § 648, at 1-2 nn.1-2. Courts therefore consider 'teaming agreements, ' as that term is normally understood within the context of government contracting.

Typically, a teaming agreement is an arrangement whereby a subcontractor will 'team' with a company intending to bid on a government contract as a prime contractor in order to pool financial and technical resources. See Northrop Corp. v. McDonnell Douglas Corp., 705 F.2d 1030, 1037 n.1 (9th Cir. 1983); Experimental Eng'g v. United Tech. Corp., 614 F.2d 1244, 1245 (9th Cir. 1980); Air Tech. v. General Elec. Co., 347 Mass. 613, 199 N.E.2d 538, 547 (Mass. 1964); see also Colsa Corp. v. Martin Marietta Servs., Inc., 133 F.3d 853, 854 (11th Cir. 1998). The subcontractor would ordinarily provide technical expertise and assist in the prime contractor's bid submission in return for the prime contractor's promise to award the subcontract. Parties to such a teaming agreement benefit from the arrangement not only ...

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