2025-LGD-0006 - JA - BIBFRAM - 2025 - Final 06062025_Redacted.pdf

Justification and Approval For Other than Full and Open Competition

Plan ID Number: 2025-LGD-0006

Form Updated 4/14/2023

Justification & Approval

As a legislative branch agency, the Library is subject to the competition and advertising requirements of 41 U.S.C. § 6101. Like the Competition in Contracting Act and the FAR, 41 U.S.C. § 6101 does not require competition when a contracting officer certifies that only one source or brand-name item is available, when dictated by public exigency, or when otherwise authorized by law.

This document sets forth the justification and approval for award of a contract or order by means providing for other than full and open competition per 41 U.S.C. § 6101, LCR 7-210, and, as applicable, FAR 6.302, FAR 13.106-1, FAR 8.405, and FAR 16.505. Contracting without competition shall not be justified on the basis of a lack of advance planning or concerns related to availability of funds.

This form shall be used to support instances where competition will be limited to a single source, a limited number of sources, including where a brand name product is required.

Part 1 – Identification

1. Contracting Agency and Activity: Library of Congress, LCSG/ABA/NDMSO

2. Nature of Action Being Approved

Contract (or modification) LoC or Leg Branch Order (or modification) GSA Schedule or GWAC: Identify Schedule/Contract Other: Identify

Plan ID Number: 2025-LGD-0006 Contractor (or Brand Name): Stefano Cossu Art and Design Estimated Value (Base and all options):

Period of Performance: Base: 6/16/2025-6/15/2026 Full with Options: 6/16/2025-6/15/2029

3. Description of Supplies or Services Required to Meet Library Needs

Describe the supplies or services that are required to meet the Library’s minimum needs, and the delivery schedule required to meet those needs. Do not focus on a description of the program.

The Library requires the following supplies or services:

The Library of Congress (Library) collects information resources from around the world and ensures their visibility and accessibility to potential users through bibliographic records. These records detail various aspects of the resources, including titles, creators’ names, publication details like publishers and places, and other pertinent information. The Library presents this information in the publications using various scripts, including numerous non-Latin scripts like Chinese, Korean, Cyrillic, Arabic, Greek, Hebrew, and over 30 additional scripts. While the Library records descriptive information in the original script of the materials being cataloged (whenever technology permits), there’s a need to transliterate certain data elements into the Latin script for different processing components and, at times, to assist end users. When technology doesn’t support non- Latin scripts, the Library staff must manually transliterate more of the descriptive information into the Latin script.

The Library maintains transliteration tables for 75 languages and scripts, ALA-LC Romanization Tables: Transliteration Schemes for Non-Roman Scripts, which are accessible on its web site: http://www.loc.gov/catdir/cpso/roman.html. These tables are collaboratively maintained by the Library and the American Library Association (ALA) and are utilized by libraries across the United States and internationally. With several million bibliographic records for resources in non-Latin scripts, the Library adds over 75,000 additional non-Latin resources to its collections annually. To facilitate this process, the Library seeks a utility capable of transliterating the non-Latin scripts into the Latin script using the approved transliteration tables.

A ScriptShifter transliterator is a utility tool or software designed to convert text from one writing system or script to another. It's particularly useful for tasks like transliterating names or phrases from one alphabet to another, such as converting Romanized text to Cyrillic or vice versa. This tool helps maintain the pronunciation or meaning of words across different writing systems. The Library’s ScriptShifter transliterator was designed to transliterate over 20+ scripts spin the Balkan/Caucasian, Slavic, Turkic, and Chinese script families, as well as Korean, Greek, Arabic, and Hebrew.

There is a need to improve the Library’s ScriptShifter transliterator to include several more scripts languages for which the Library regularly receives substantial resources. Additionally, its design should be analyzed to enhance efficiency and accommodate an increased number of supported scripts languages.

The contractor shall provide highly specialized expertise and technical services to update, design, code, test, improve, and document the Library’s ScriptShifter transliterator to include several additional script languages, and its design must undergo review and analysis to improve efficiency and adapt to the increased number of supported scripts. The Library will supply a general design for the programs and information on how the programs should interface with the Library’s BIBFRAME and other systems.

The contractor shall ensure compatibility with the Library’s existing transliterator systems and add additional non-Latin script languages, including but not limited to, Thai, Lao, Khmer, Tibetan, Burmese, Devanagari, Yiddish, Arabic, Pushto, Sindhi, Kurdish, Persian, Urdu and other languages in the Indian continent. Also, the contractor shall research on developing a Japanese transliteration tool. Further, the contractor shall update the ScriptShifter to carry out reverse transliteration and review the entire transliteration file systems. The contractor shall research and report, provide designs with Library approval, perform testing, optimization, and shall document all files and perform quality control.

Part 2 – Program Office Justification & Approval

4. Authority for Contracting Without Competition Over $250,000 For this requirement over $250,000, under FAR part 6, the basis for contracting without providing for full and open competition is:

There is only one responsible source and no other supplies or services will satisfy Library requirements.

41 U.S.C. § 6101(b)(2)(C); FAR 6.302-1.

Library’s minimum needs can only be satisfied by contractor’s unique capabilities or products. FAR 6.302-1(b)(1).

Source controls copyrights, patents, raw materials, or secret processes cannot be acquired otherwise, or similar circumstances. FAR 6.302-

1(b)(2).

Other exception identified in FAR 6.302-1: Identify the exception

There is such unusual & compelling urgency that the Government would be seriously injured if competition is not limited.

41 U.S.C. § 6101(b)(2)(B); FAR 6.302-2. Option years are not permitted.

Source is expressly authorized or required by statute (e.g., AbilityOne, UNICOR, GPO, GSA Public Buildings Service, Appropriations Act, etc.) per 41 U.S.C. § 6101(b)(1) and FAR 6.302-5: Identify the authority

Other basis authorized in 41 U.S.C. § 6101(b) or FAR part 6.302: Identify the exception

Library’s needs can only be satisfied by a brand-name product or item which is essential to the Government’s requirement. FAR 6.302-1(c).

The Product is listed on the Library of Congress Enterprise Architecture Repository (LCEAR) database (Attach applicable

IT Standard Data Sheet)

Up to and including $250,000 For this requirement up to $250,000, using simplified acquisition procedures under FAR part 13, the basis for contracting without providing for full and open competition is:

Only one responsible source is reasonably available to meet Library requirements. 41 U.S.C. § 6101(b); FAR 13.106-1.

Product or service is reasonably available from only one source.

Source controls copyrights, patents or other exclusive licensing arrangements.

Urgent circumstances; only one source can reasonably deliver by required date. Option years are not permitted.

Source is expressly authorized or required by statute: Identify the authority

Library’s needs can only be satisfied by a brand-name product The Product is listed the Library of Congress Enterprise Architecture Repository (LCEAR) database (Attach applicable

IT Standard Data Sheet)

GSA Schedule Order For this GSA schedule order under FAR part 8, the basis for not competing among GSA schedule-holders and/or specifying a brand name product or item is:

An urgent and compelling need exists, and following GSA procedures would result in unacceptable delays.

FAR 8.405-6(a)(1)(i)(A).

Only one GSA source is capable of fulfilling the requirement at the level of quality required because the supplies or services are unique or highly specialized. FAR 8.405-6(a)(1)(i)(B).

In the interest of economy and efficiency, the new work is a logical follow-on to an original order that was placed competitively among GSA schedule-holders (i.e., the original order was not sole-source or limited-source.) FAR 8.405-6(a)(1)(i)(C).

Library’s needs can only be satisfied by a brand-name product The Product is listed on the Library of Congress Enterprise Architecture Repository (LCEAR) database (Attach applicable

Order Under Multiple Award Indefinite-Delivery Contract or GWAC For this order under FAR subpart 16.5, the basis for contracting without providing for full and open competition is:

The need is so urgent fair opportunity would result in unacceptable delays. 41 U.S.C. § 6101(b)(2)(C) and FAR 16.505(b)(2)(i)(A).

The Library’s minimum needs can only be satisfied by contractor’s unique capabilities or products. 41 U.S.C. § 6101(b)(1) and FAR

16.505(b)(2)(i)(B).

A logical follow-on order in the interest of economy and efficiency. 41 U.S.C. § 6101(b)(1) and FAR 16.505(b)(i)(2)(C).

To satisfy a minimum guarantee. 41 U.S.C. § 6101(b)(1) and FAR 16.505(b)(2)(D).

Authorized or required by statute. 41 U.S.C. § 6101(b)(1) and FAR 16.505(b)(2)(E).

The Library’s minimum needs can only be satisfied by a brand-name product or item which is essential to the Government’s requirement. 41

U.S.C. § 6101(b)(2)(B) and FAR 16.505(a)(4)(i).

The Product is listed on the Library of Congress Enterprise Architecture Repository (LCEAR) database (Attach applicable

5. Rationale for Contracting Without Competition

In supporting an action not providing for full and open competition, it is not sufficient to demonstrate that the contractor is exceptionally well qualified or even the best qualified, or that the required brand name product is well suited to the Library’s needs. The rationale must demonstrate that no one else, or no other competing product, can satisfactorily fulfill the Library’s requirement. Do not focus on the importance of the requirement; the issue is the rationale for not competing.

In supporting urgency, address the following: What are the unexpected facts or the unpredictable events that led to this situation? When is the required delivery or performance start date? Why this date? What specific harm to the Government will occur if the delivery is not made or performance not begun as scheduled? (Note that expiration of funds is not sufficient harm to justify not competing.) Demonstrate that the contract is only for items and quantities urgently needed until a competitive procurement action can be developed, or that a separate competitive follow-on is not practical.

In supporting a brand name justification, the brand name or feature must be essential to the Library’s requirements, and market research indicates that other company’s similar products or products with similar features cannot meet or be modified to meet the Library’s needs.

We are authorized to limit competition on the basis of the citation in section 4 because:

This justification is based on only one responsible source will satisfy the Library requirements because this contract is for services of a follow-on contract for the continued development of a highly specialized system. The justification is that Stefano Cossu has developed ScriptShifter and is the specialized expert with an in-depth understanding who can create a more efficient and more precise tool that meets the Library’s needs. No other sources will satisfy the Library’s requirements because it would create a substantial duplication of costs to the government that is not expected to be recovered through competition.

Stefano Cossu developed the ScriptShifter transliterator on the Library’s previous contract and has specialized expertise in linguistic technologies and transliteration algorithms, making this company uniquely qualified to meet the Library’s requirements. Specialized experts mean the developers have an in-depth knowledge and understanding of the intricacies and complexities involved in transliteration algorithms. These specialized experts create a more efficient and effective solutions as they are familiar with best practices, optimization techniques in developing the ScriptShifter tool. Further, specialized expertise results in more precise and accurate ScriptShifter tool that meets the Library’s needs more effectively. Stefano Cossu has intimate knowledge of the Library’s ScriptShifter transliterator tool. This specialized knowledge makes this company the only reasonable source for the enhancement.

The ScriptShifter transliterator tool has been specifically tailored to the Library’s needs developed by Stefano Cossu, incorporating unique features and functionalities that address the Library’s specific uses. Stefano Cossu is familiar with the Library’s needs which enables them to efficiently address the Library’s requirements. Since Stefano Cossu has already developed tailored customization for the ScriptShifter tool, they can build upon existing work which increases efficiency and reduces time and effort required to implement new customizations or enhancements. Continuity in working with Stefano Cossu ensures consistency and quality standards which minimizes disruptions and maintains the integrity of the Library’s customized solutions.

This contract is to expand the existing ScriptShifter transliteration tool by integrating various script languages and examination of internal ScriptShifter files since several very large character sets will be added. Stefano Cossu has developed deep knowledge of the Library’s existing systems, enabling seamless integration of the ScriptShifter. Stefano Cossu is already familiar with the Library’s databases, APIs and other software components and has previously integrated ScriptShifter tool with the Library’s systems, they understand the integration points, data formats, and technical requirements involved, which enables them to integrate more efficiently.

6. Actions to Overcome Barriers to Competition Before Subsequent Contract Is Required

State what actions, if any, the program office can take to overcome barriers to competition before a contracting for this requirement again, such as:

using action to provide time to develop specifications for a competitive procurement by a certain date; licensing copyrights or patents so other contractors may use the works; or breaking the requirement into parts that may be purchased competitively. If this is a one-time requirement, explain that action to increase future competition is not needed. If the source is expressly required by statute, state “Source is statutory.”

To increase competition, we will: The Library will continue to evaluate future transliteration work of other applications to determine if new techniques by alternative sources are emerging that could be incorporated into the transliterate utility.

7. Program Office Certification

I certify that the description of the Government’s minimum needs, schedule requirements, and technical information that provide the basis for this justification are accurate and complete.

Name

Title

Signature

Date

0BPART 3 – CONTRACTING OFFICER DETERMINATIONS & CERTIFICATION

8. Efforts to Solicit from As Many Potential Sources As Practicable Unless a justification is based on FAR 6.302-2, Unusual and compelling urgency, contracting officers shall post justifications for other than full and open competition, including brand name justifications, to the Contract Opportunities website on sam.gov (or eBuy for Brand Name Justifications under FAR Part 8) prior to requesting a proposal or otherwise entering into negotiations.

Advance notice will be published in sam.gov for 15 days before a contract is awarded. FAR 5.203(a).

Advance or concurrent notice will be published in sam.gov for a reasonable time for commercial items FAR 5.203(a) and 12.204(b).

Advance notice will not be published because the action meets the following FAR exception:

Notice would compromise national security. FAR 5.202(a)(1).

Unusual and compelling urgency; notice period would seriously injure Government. FAR 5.202(a)(2).

Expressly authorized or required to be made through another Government agency. FAR 5.202(a)(4).

Order will be placed against an IDIQ contract awarded under FAR 16.5. FAR 5.202(a)(6).

Order will be placed against GSA schedule or other competitively-awarded contract. FAR 5.202(a)(11).

Other:

Advance notice will not be published per 41 U.S.C. § 6101; see attached deviation from the FAR per LCR 7-210 § 3.A.

We made the following efforts to interest potential sources in this award: None

9. Listing of Sources That Expressed Interest in Writing

The following sources expressed interest in this award: N/A

10. Additional Information

The following additional information is relevant to this justification and approval: The Library has invested into the current ScriptShifter transliterator that is being used and needs only to expand its capability and improve efficiency as it adds additional languages. A competition that would require examining new solutions are outside of the scope of this effort and funding available for this effort.

11. Contracting Officer Determination that Price Is Fair and Reasonable As explained in detail below, I have determined that the prices for this contracting action are fair and reasonable based on comparison of the prices to the following (see FAR 15.404-1(b)(2)):

Historical prices paid by the Government Published competitive price lists Library’s Independent Government Estimate Prices obtained through market research Other: Prices obtained through competitive proposals

The following analysis (based on attached pricing information) supports my determination: Analysis will be perform prior to award after pricing has been established.

12. Contracting Officer Determination of Responsibility Checked System for Award Management (or will check in the case of competitive proposals for a brand name product)

13. Contracting Officer Determination of Best Value I have determined that this action represents the best value to the Government because: This will be done at time of award.

14. Contracting Officer Certification I certify that, to the best of my knowledge and belief, this justification is accurate and complete. For those actions up to $750,000, I approve contracting without competition for this requirement.

Betsy T. Lewis-Matsuoka Name

Signature

06//06/2025 Date