We recommend that the Under Secretary of Commerce for Intellectual Property and Director of the United States Patent and Trademark Office direct the Director of the Office of Procurement to develop controls to prevent unnecessary or unreasonable costs, such as the $22,418,462 in questioned costs, by (a) developing procedures to define the structure, roles, and communication methods of the offices and individuals on an acquisitions team and (b) completing Patent and Trademark Acquisition Manual guidance on the reasonableness of noncompetitive acquisitions.