47QFEA25K0021_LSJ_DataEnrichment_2025-05-20_Redacted.pdf

CUI//SP-SSEL

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LIMITED SOURCES JUSTIFICATION (LSJ)

For

FAS Data Enrichment Support in support of:

GSA, FAS, Catalog Management Office (CMO)

Acquisition ID Number: 47QFEA25K0021

United States (U.S.) General Services Administration (GSA)

Federal Acquisition Service (FAS)

Assisted Acquisition Services (AAS) Civilian

Interagency Agreement Number: 47QFEA25S0003

Controlled by AAS Contracting Officer: rick.yao@gsa.gov

05/20/2025

Docusign Envelope ID: 6B36E455-3B01-4F7F-84C0-030312AC1153

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The General Services Administration (GSA) Assisted Acquisition Services (AAS) makes this

Limited Sources Justification (LSJ) for orders pursuant to Federal Acquisition Regulation (FAR)

8.405-6.

i.) Identification of Agency and Contracting Activity:

Agency:

GSA AAS acting in support of GSA, FAS, Catalog Management Office (CMO)

Contracting Activity:

GSA AAS Contracting Office (QFCAAB) Civilian ii.) Nature and/or Description of Action Being Approved:

The action being approved is a sole source award of a task order via the GSA Multiple

Award Schedule (MAS) contract to XSB, Inc., under its GSA MAS Contract Number:GS-

35F-0318X, for Software Subscription and Data Enrichment Web Service Support in the total estimated amount of $6,739,675.78. The task order will include a one-year base period, with four (4) one-year option periods. The anticipated award will be a hybrid contract type, on a Firm-Fixed Price (FFP) and Time-and-Materials (T&M) basis.

iii.) A Complete Description of Supplies/Services Required to Meet Agency’s Need

(Including the Estimated Value): $6,739,675.78

This requirement is for the acquisition of software subscription and data enrichment services to support GSA/FAS enterprise-wide pricing and catalog management capabilities.

GSA manages over 80 million awarded contract line items, many of which are described inconsistently across vendors due to variations in manufacturer names, part numbers, and branding conventions. These inconsistencies significantly hinder the ability to accurately identify comparable items, evaluate price reasonableness, and detect regulatory compliance risks—especially when standardized identifiers like barcodes or Global Trade Item

Numbers (GTINs) are absent.

The software includes price analysis and evaluation, and price benchmarking/negotiation reports along with enhanced product data standardization and enrichment. The software subscription leverages a patented AI engine, which was developed specifically to resolve the differences in manufacturer names, part numbers, and brand representations to discover identical products described differently across the supply chain. This is done via an automated process using proprietary algorithms, statistical matching, and a global knowledge base of millions of products. Utilizing Artificial Intelligence (AI), XSB, Inc. 's system is specifically tuned and trained on company brands, affiliations, and other product associations common to items in the government supply chain. The system identifies functionally equivalent products—even when they are described differently and lack common identifiers—enabling scalable, automated product normalization, pricing comparison, and compliance screening. Crucially, XSB, Inc. doesn’t just power the

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Verified Products Portal (VPP)—it fully integrates it into its AI model. This allows supplier authorizations, enriched product content (e.g., specifications, images, PDFs), and prohibition rules to feed directly into the same AI framework used for compliance and pricing analysis.

The annual license allows for unlimited use of XSB, Inc.'s Data Enrichment Web Services and consists of three components: the Price Point Plus License, Verified Products Portal

(VPP), and the Compliance & Pricing Reporting Portal (CPRP). The VPP enables GSA, manufacturers, wholesalers, and vetted distributors to submit product content data and supplier authorization data. This authoritative VPP content is utilized to apply thousands of prohibition rules to each item analyzed through a 40+ step workflow to ensure compliance and reduce procurement risk for the Agency. This powerful combination of AI and automation is unique to XSB, Inc.’s Price Point system and would be difficult for another supplier to replicate. CPRP is a web-based portal that facilitates on-demand market research for GSA AWF. The VPP and CPRP were developed by XSB, Inc. and are directly integrated with XSB, Inc.’s product data standardization and enrichment web service.

XSB, Inc. services are backed by a global item master database of 100 million items of supply. This database contains rich, structured information on commercial parts, suppliers, logistics, price, and regulatory data from both government and commercial sources.

Presently, FAS leverages the existing data enrichment web service to conduct approximately 12,000 actions per year consisting of more than 228 million items screened.

In addition to the software subscription, the requirement includes Enhancements CLINs to support customization of the data enrichment web service to meet GSA’s requirements and ensure high availability and adherence to the level of service performance standards.

Enhancement support includes maintenance and improvements to the VPP and CPRP.

iv.) The Authority and Supporting Rationale:

The acquisition is conducted under the authority of the Multiple-Award Schedule (MAS)

Program. Consideration of schedule contractors will be restricted in accordance with:

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

The Federal Acquisition Regulation (FAR), General Services Acquisition Manual

(GSAM), and an assortment of FAS policies require the Contract Specialist/Contracting

Officer (CS/CO) to find proposed prices to be fair and reasonable prior to award. The use of a pricing tool is very helpful with making this determination, particularly when transactional data is not readily available. One of GSA’s most important and influential innovations was the creation of a database pricing tool that captured awarded pricing from

Federal Supply Schedules (FSS) contracts and enabled the FAS Acquisition Workforce

(AWF) to efficiently conduct horizontal price comparisons as part of the overall price analysis on offers and pricing-related modifications. The database pricing tool information

Version 02/28/2025 was critical in the formation of a web-based tool available to the entire AWF and industry partners to conduct market research. To assist the AWF, FAS has established a centralized pricing and supply chain risk analytics team within FAS CMO. This team is tasked with leveraging GSA’s existing data sources and tools to provide high quality market intelligence and analytical support for the FAS AWF. This requirement is in direct support of these activities.

In FY24, members of the FAS, AWF leveraged GSA’s pricing tools, most notably the

Price Point Plus Portal (4P) and the Compliance and Pricing (CnP) Report within the FAS

Catalog Platform (FCP), to screen 228 million items. Screening through GSA’s pricing tools resulted in more than 7.3 million SCRM and regulatory compliance issues, including

Section 889 prohibited items, unauthorized suppliers, non-TAA items, MiA misrepresentations and Essentially the Same (ETS) Ability One items. The screening process ensures that products are sourced from countries with trade agreements with the

United States and that items are not offered from manufacturers that pose a national security risk, (i.e., Kaspersky Lab, Huawei Technologies Company, ZTE Corporation). In fact, 33% (4,205 out of 12,701) of actions run through the FCP and 4P tool in FY24 had regulatory compliance or SCRM concern flags.

XSB, Inc. has provided the annual subscription and support services for the past five (5) years under Task Order Number:47QFWA20F0015. XSB, Inc.’s high quality market analysis has enabled FAS AWF to perform line-item level screening for both pricing and compliance. Active users in every GSA Business line rely on the insights derived from

XSB, Inc. 's software and associated services to make fair and reasonable price determinations and guard against the procurement of items that pose a national security risk or are otherwise prohibited by regulation.

Failure to provide this service will jeopardize the mission of the FAS acquisition workforce. Presently, FAS has multiple tools and applications that rely upon a static unique item identifier. The Information Architecture (IA) is proprietary to XSB, Inc. Shifting to a new standard for unique item identifiers would cause a significant disruption and result in additional development work as well as the loss of trend analysis capability. The requirement necessitates the contractor to be capable of performing the day following task order award to ensure no disruption to FAS’ operation. The decision to issue the RFQ to

XSB, Inc. takes into account the Government’s need for continuity of operations and the potential costs of disrupting operations.

MAS and Federal Supply Schedules provide federal, state, and local Government buyers access to over 80 million supplies, products and services valued at $50 billion per year. The task order will make it easier for agency partners to buy products, services and solutions.

Additionally, FAS seeks to provide its acquisition workforce with the best available tools to improve the management and analysis of an increasingly broad scope of products and awarded contract prices.

XSB, Inc. is the only capable contractor that will be able to provide software licensing as they are the sole proprietor of the software. The annual software license cannot be purchased from another Schedule or GSA MAS Contractor. It would not be feasible nor cost effective to split this requirement (which consists of the software licenses and

Version 02/28/2025 upgrades to the software) to satisfy this requirement. Due to the proprietary nature of the software licenses, no other Information Technology professional would be qualified nor authorized to make enhancements to the proprietary software.

v.) Determination by the Ordering Activity Contracting Officer that the Order

Represents the Best Value Consistent with FAR 8.404(d):

The total estimated value of the task order is $6,739,675.78, which includes one (1) base year and four (4) one-year option periods. The task order total was arrived at using XSB, Inc.’s current pricing and labor rates under its GSA MAS contract GS-35F-0318X. Fair and reasonable pricing will be determined by the Contracting Officer’s price analysis of the price quote submission. The labor categories and hourly rates will be verified in accordance with the rates and Independent Government Cost Estimate (IGCE). In accordance with

FAR 8.405-6(c)(2)(v), a determination is made by the undersigned Contracting Officer that this order will represent the best value for the Government consistent with 8.404(d). In accordance with FAR 8.404(d), GSA has already determined the hourly rates for services offered at hourly rates, under GSA MAS contracts to be fair and reasonable. Therefore, ordering activities are not required to make a separate determination of fair and reasonable pricing, except for a price evaluation as required by 8.405-2(d).

vi.) Description of the Market Research Conducted Among Schedule Holders and the

Results of the Research:

Based on market research and internal analysis—including findings from the last full and open competition—it is clear that no other vendor on the GSA Schedule offers the same level of AI-driven capability, integration, and scale as XSB, Inc. XSB, Inc. remains the only provider delivering a fully integrated solution that combines automated pricing analysis, supply chain risk mitigation (SCRM), product normalization, and regulatory compliance screening tailored to GSA’s specific operational needs.

XSB, Inc.’s proprietary Information Architecture (IA), developed and refined over the years, is deeply embedded within GSA’s catalog and pricing infrastructure. This integration has enabled the processing of more than 228 million items and the creation of a government-specific product database exceeding 100 million records. It supports compliance with complex federal regulations—including the Trade Agreements Act

(TAA), Section 889, and national security directives—while ensuring uninterrupted operations across GSA/FAS systems.

To date, no vendor has been identified that offers a comparable solution capable of performing product normalization, government-specific pricing analytics, and regulatory compliance checks—particularly in the absence of standardized identifiers like barcodes or

GTINs. While some vendors provide limited features such as price comparison or basic product content enrichment, none match XSB, Inc.’s AI-driven ability to resolve duplicative product descriptions and integrate those results with pricing and compliance logic tailored to federal acquisition. This level of end-to-end integration is critical to supporting the scale and complexity of GSA’s operations.

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Replacing the current system would require extensive reintegration, large-scale data migration, redevelopment of compliance logic, and reengineering of existing workflows.

Internal estimates place the cost of such an effort at over $50 million over five years, with a high risk of operational disruption, data degradation, and compliance gaps. In contrast, XSB, Inc.’s existing solution is fully deployed, cost-effective, and aligned with current budget constraints.

Moreover, XSB, Inc. was the sole respondent to the last full and open RFQ, underscoring the absence of viable alternatives in the marketplace. Taken together—market research, historical program data, technical assessments, and vendor response history—clearly demonstrate that replacing XSB, Inc. would be neither technically viable nor financially practical without jeopardizing GSA’s mission-critical pricing and catalog operations.

In accordance with FAR 8.002(a)(1)(i) through (vi), the Contracting Officer has determined that the requested XSB software and services are not available from other priority Government supply sources, such as the Federal Prison Industries and AbilityOne

Program. The best acquisition alternative for the Government is the use of the MAS program, since this software and services are available on GSA Schedule. Market research obtained from GSA Advantage! indicates that there are 1095 contractors listed under GSA

Schedule 511210-Software License, and 5165 contractors listed under 54151S-Information

Technology Professional Services, but only one GSA contractor was found to offer the

XSB platform software: XSB, Inc. (GS-35F-0318X). The requirement needs to be awarded by 11/15/2025, so that the software will be available for use in the new period of performance beginning 12/01/2025. The Contracting Officer reviewed GSA e-library to verify XSB, Inc. held an active GSA Federal Supply Schedule (FSS). The System Award

Management was reviewed and XSB, Inc. is active and in good standing.

vii.) Any Other Facts Supporting the Justification:

As the current subscription for the required services will expire on 11/30/2025, a subscription renewal needs to be in place in order for uninterrupted services beginning on

12/01/2025. Without an order in place, access to critical price analysis will be interrupted, jeopardizing FAS’ ability to accurately determine the reasonableness of prices proposed by contractors and meet their mission.

Failure to place a timely order would also compromise FAS’ SCRM and regulatory compliance screening capabilities. A break in service would result in an exponential increase in the number of contract items that pose a national security risk or are otherwise prohibited by regulation. These include Section 889 prohibited products, Non-TAA compliant, Unauthorized supplier identification, AbilityOne Essentially-the-Same (ETS) items.

viii.) Statement of the Actions, if Any, the Agency May Take to Remove or Overcome any

Barriers that Led to the Restricted Consideration Before Any Subsequent Acquisition for the Supplies or Services is Made:

FAS CMO has previously conducted market research and explored alternative solutions, including engagement with a commercial provider. However, these efforts confirmed that

Version 02/28/2025 no commercially available vendor currently offers the integrated capabilities required— namely, AI-enabled product standardization, regulatory compliance screening, and government-specific pricing analytics—particularly without dependence on GTINs or other universal product identifiers.

That notwithstanding, FAS CMO acknowledges the importance of pursuing long-term strategies to mitigate the risk of proprietary vendor lock-in. One potential pathway involves promoting broader adoption of GTINs or other open data standards across the federal supply chain and among industry partners. If successfully implemented, these standards could enable GSA to incrementally build internal capabilities to perform select functions currently fulfilled by XSB, Inc.

However, developing such an alternative would necessitate a multi-year investment in policy development, IT infrastructure modernization, enterprise data standardization, and workforce upskilling. It would also require the replication or development of highly specialized AI capabilities that are not presently available through other sources.

Furthermore, any prospective replacement vendor would likely introduce proprietary technologies of their own, potentially leading to integration risks and challenges comparable to those associated with the current system.

While industry engagement activities—such as hosting Industry Days, issuing Requests for

Information (RFIs), and conducting technical market assessments—represent prudent actions in support of long-term acquisition planning, FAS CMO does not currently possess the necessary resources or budget to pursue a transition of this scale without adversely impacting existing mission-critical operations.

That said, FAS CMO is proactively engaged in the development of a new requirement to mitigate future reliance on a sole-source environment and avoid additional proprietary tool dependencies. Over the next one to two years, FAS CMO intends to initiate a full and open recompete process. This effort will include structured industry engagement, such as

Industry Days with technical demonstrations, to promote robust competition and enable the market to better align with GSA’s unique product standardization and compliance needs.

However, the development and execution of such a strategy will require additional time, resources, and sustained coordination across technical, acquisition, and policy stakeholders.

Accordingly, this LSJ is being submitted to authorize continued use of XSB, Inc.’s software in the interim. The intent is to ensure continuity of operations and avoid disruption to critical pricing and compliance functions while FAS CMO works to shape a competitive acquisition strategy for the future.

ix.) Contracting Officer Certification that the Justification is Accurate and Complete to the Best of the Contracting Officer’s Knowledge and Belief:

I hereby certify that this Justification is accurate and complete to the best of my knowledge, and I determine on the basis of the findings above that the limited sources approach is in accordance with the requirements and is in the best interest of the Government.

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Rick Yao Date

Contracting Officer

GSA/FAS/AAS Civilian x.) Evidence that any Supporting Data that is the Responsibility of Technical or

Requirements Personnel and Which Form a Basis for the Justification Have Been

Certified as Complete and Accurate by the Technical and Requirements Personnel (If

Any):

Supporting data provided by technical or requirements personnel has been certified as complete and accurate as demonstrated by the COR, Michael Shepherd.

xi.) Written Determination by Approving Official Identifying the Circumstance that

Applies:

I hereby certify that this justification is accurate and complete to the best of my knowledge, and I determine on the basis of the findings above that the Limited Sources Justification is in accordance with the requirements and is in the best interest of the Government.

Contracting Officer

GSA/FAS/AAS Civilian xii.) Reviews/Approvals

I have reviewed this justification, and I have determined to the best of my knowledge and belief, based on the information contained herein, that it complies with all applicable policies and regulations.

Contracting Officer

GSA/FAS/AAS Civilian