7c SC 5000225320 Treasury SF 1014 JEFO 8.21.26.doc 1.pdf
Standard Form PDF 619 KB Posted
- Attached to
- Gigamon End of Life (EOL) Expansion Support
- Solicitation number
- 205AE9-26-Q-00107
About this file
This is a Standard Form 1014 (SF 1014) Justification for an Exception to Fair Opportunity submitted by the Department of Treasury's Internal Revenue Service (IRS) for a "Gigamon EOL & Expansion" acquisition.
The IRS seeks approval to award a Firm Fixed Price contract for the brand name acquisition, purchase, and update of commercially available proprietary Gigamon software licenses and associated maintenance services. The requirement includes procurement of new and additional hardware, software licenses, and maintenance services to replace end-of-life components and expand the current deployment to support the IRS Cybersecurity Operations Computer Security Incident Response Center (CSIRC) and Network Management Control Center (NMCC). The base performance period runs from September 14, 2026 through September 13, 2027, with four optional one-year renewal periods extending through September 13, 2031. The estimated total contract value is $10,563,975.87, comprising a base year of $3,486,039.70 and option periods ranging from $1,594,150.20 to $1,952,902.63 annually. The IRS invoked the exception to fair opportunity under FAR 16.505(a)(4), asserting that the requirement is for an item peculiar to one manufacturer (brand name specifications). The justification documents extensive market research evaluating eighteen commercial packet-broker vendors, with only Gigamon, Keysight, and Cisco Nexus Dashboard Data Broker advancing to final testing. Gigamon met all 18 must-have requirements and 4 should-have requirements, while Keysight and Cisco each fell short on critical capabilities including IPv6 compliance, ERSPAN aggregation, agent-based decryption, and cloud-environment integration. The document notes that Gigamon is the only evaluated COTS solution meeting IRS's full technical and operational requirements for enterprise-scale packet brokering at production traffic levels. Award will be made through NASA SEWP V authorized resellers using lowest priced technically acceptable (LPTA) criteria. The NAICS code is 541519 with PSC code 7G21.
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DEPARTMENT OF THE TREASURY
SF 1014 - JUSTIFICATION FOR AN EXCEPTION
TO FAIR OPPORTUNITY
ACQUISITION TITLE: “Gigamon EOL & Expansion”
Treasury Standard Form – 1014 (Rev 12/24)
Prescribed by Treasury: DTAP 1016.505
Tracking No.
1. Identification of the requiring activity and the contracting activity:
The requiring activity is the Internal Revenue Service (IRS) / Office of the Chief Procurement
Officer (OCPO), Information Technology Operation Division, Enterprise Operations Branch (EOps).
2.a Nature and/or description of the action being approved:
The purpose of this JEFO is to obtain approval to award a Firm Fixed Price to procure approval for the brand name acquisition, purchase, and update of commercially available proprietary
Gigamon software licenses and associated maintenance.
This requirement includes the procurement of new and additional hardware, software license, and maintenance services to replace components approaching end-of-life and to expand the current deployment to meet increased operational demands, maintain vendor support, ensure continued network visibility, security monitoring, and performance reliability
Period of Performance:
Base Year: 9/14/2026 - 9/13/2027
Option 1: 9/14/2027 - 9/13/2028
Option 2: 9/14/2028 - 9/13/2029
Option 3: 9/14/2029 - 9/13/2030
Option 4: 9/14/2030 - 9/13/2031
2.b Name of the vendor. TBD
2.c Requisition No.: 5000225320
2.d Bridge contract: □ Yes � No 2.e Brand name: � Yes □ No
3.a A description of the supplies or services required to meet the agency’s needs:
The objective of this requirement is to acquire IRS owned Commercially Off-the-Shelf
(COTS) proprietary Gigamon hardware appliance, software, and maintenance for the IRS
Cybersecurity Operations Computer Security Incident Response Center (CSIRC) and the
Network Management Control Center (NMCC). The Gigamon appliances consist of hardware, software, licenses and configurations supporting intrusion detection technology for CSIRC and packet distribution technology for the Trusted Internet Connection (TIC)
Common Communication Gateway (CCG).
The IRS requires new Gigamon hardware appliance, software licenses, and associated maintenance to replace end-of-support items and expand the existing Gigamon network. The required Gigamon components provide:
• High-throughput packet brokering at enterprise scale
• Traffic aggregation, filtering, de-duplication, and load balancing
• Metadata and SSL/TLS visibility critical to CSIRC operations
• Reliable operation under full IRS production traffic levels
• Integration with existing CSIRC and NMCC monitoring infrastructure
3.b Includes IT: � Yes □ No NAICS: 541519 and PSC: 7G21
TO FAIR OPPORTUNITY
ACQUISITION TITLE: “Gigamon EOL & Expansion”
Treasury Standard Form – 1014 (Rev 12/24)
3.c IGCE/Estimated dollar value:
The IGCE contains a 12-month Year, and four 12-month option periods.
Base Period (9/14/2026 – 9/13/2027) $ 3,486,039.70
Option Period 1 (9/14/2027 – 9/13/2028) $ 1,594,150.20 Option Period 2 (9/14/2028 – 9/13/2029) $ 1,705,740.69 Option Period 3 (9/14/2029 – 9/13/2030) $1,825,142.65 Option Period 4 (9/14/2030 – 9/13/2031) $1,952,902.63 Estimated Total $10,563,975.87
4.a Identification of the exception to fair opportunity being used:
□ FAR 16.505(b)(2)(i)(A) – The agency need for the supplies or services is so urgent that providing a fair opportunity would result in unacceptable delays.
□ FAR 16.505(b)(2)(i)(B) – Only one awardee is capable of providing the supplies or services required at the level of quality required because the supplies or services ordered are unique or highly specialized.
□ FAR 16.505(b)(2)(i)(C) – The order must be issued on a sole-source basis in the interest of economy and efficiency because it is a logical follow-on to an order already issued under the contract, provided that all awardees were given a fair opportunity to be considered for the original order.
□ FAR 16.505(b)(2)(i)(D) – It is necessary to place an order to satisfy a minimum guarantee.
□ FAR 16.505(b)(2)(i)(E) – For orders exceeding the simplified acquisition threshold, a statute expressly authorizes or requires that the purchase be made from a specified source.
� FAR 16.505(a)(4) – The requirement is for an item peculiar to one manufacturer. (i.e., Brand Name specifications)
4.b Supporting rationale:
The IRS requires continued support, refresh, and expansion of its enterprise packet broker infrastructure to maintain mandatory cybersecurity visibility across Trusted Internet Connection
(TIC) locations and other enterprise network traffic points. The Computer Security Incident
Response Center (CSIRC), Network Management Control Center (NMCC), and related engineering/security operations rely on packet broker appliances to aggregate, filter, decrypt where authorized, load balance, and distribute network traffic to monitoring, cybersecurity, and diagnostic tools. Without continued vendor-supported packet broker capability, the IRS would lose or degrade visibility into production traffic, impair incident detection and response, and create unacceptable operational and cybersecurity risk to mission-critical tax administration systems.
This requirement is driven by Federal cybersecurity mandates and IRS operational need. The
Executive Office of the President and the Department of Homeland Security require Federal agencies to monitor TIC locations, and TIC 3.0/OMB guidance requires agencies to maintain visibility, control, logging, and policy enforcement capabilities across enterprise traffic flows. To meet these requirements, the IRS must be able to pass high-volume production traffic from TIC and enterprise network locations to CSIRC, NMCC, and other monitoring tools without packet loss, traffic interruption, or degradation of security analysis. The IRS WAN supports hundreds of IRS
TO FAIR OPPORTUNITY
ACQUISITION TITLE: “Gigamon EOL & Expansion”
Treasury Standard Form – 1014 (Rev 12/24) sites and critical platforms, including filing-season operations, contact centers, enterprise messaging, portals, remote access, development/test environments, intranet, and internet connectivity. As a result, the packet broker solution must operate reliably at IRS enterprise scale, not merely in a limited laboratory or minimum functional environment.
The current enterprise packet data broker solution was awarded to Gigamon to provide network visibility, traffic aggregation, and traffic management capabilities across the IRS enterprise environment. In preparation for that award, the IRS conducted extensive market research and technical evaluations over a one-year period to assess alternative data broker solutions capable of meeting both current and projected operational requirements. Initial testing of alternative solutions demonstrated the ability to meet basic functional requirements in controlled laboratory environments. However, during extended testing and under increased traffic volumes representative of IRS production workloads, those solutions exhibited scalability and performance limitations. Empirical test results showed that when scaled to enterprise operational demand, alternative products experienced performance degradation, including packet loss and traffic interruption, indicating an inability to reliably support sustained production-level operations.
The IRS evaluated Cisco Nexus Dashboard Data Broker and assessed Keysight packet broker capabilities for engineering and analytical use cases. While both solutions demonstrated success at a minimal functional level, neither was able to meet full IRS operational requirements during extended testing or at production-scale traffic levels. These limitations presented unacceptable operational risk to enterprise network visibility, monitoring, and security functions.
The IRS evaluated the packet broker marketplace and focused detailed consideration on Gigamon, Keysight, and Cisco Nexus Dashboard Data Broker because these three represented the strongest apparent fit for the IRS requirement among market-leading network packet broker solutions. Cisco was included because the IRS currently operates a substantial Cisco network environment, and
Cisco Nexus Dashboard Data Broker warranted review for potential interoperability with existing
Cisco equipment, Nexus switching, and data center fabric architecture. Other vendors identified in the broader marketplace were not advanced for detailed evaluation because available market research did not demonstrate that they met the IRS’s must-have requirements for enterprise-scale packet brokering, IPv6 operation, Federal/IRS accessibility and authentication needs, high-availability/redundancy, aggregation of SPAN/TAP/tunneled feeds, agent-based decryption, third-party tool output, filtering, smart packet processing, multi-chassis/distributed management, cloud-environment support, 10/40/100G line-rate operation, transceiver compatibility, FIPS 140-2
SSL/TLS certification, and full packet delivery to attached tools.
The IRS’s must-have requirements were used to screen alternatives because a failure to satisfy, or failure to demonstrate satisfaction of, any essential requirement would create unacceptable risk to cybersecurity monitoring, network visibility, and operational continuity. The broader market scan identified eighteen commercial packet-broker vendors or architectures. Of those, fifteen were not advanced to the final testing phase because initial screening and available technical information did not demonstrate that they satisfied the IRS’s essential must-have requirements for enterprise-scale packet brokering, including IPv6 operation, Section 508/IRM support, redundancy, TO FAIR OPPORTUNITY
ACQUISITION TITLE: “Gigamon EOL & Expansion”
Treasury Standard Form – 1014 (Rev 12/24)
PIV/SSO authentication, SPAN/TAP/ERSPAN aggregation, agent-based decryption, third-party tool output, filtering, smart packet processing, distributed chassis management, integrated cloud-environment support, 10/40/100G line-rate operation, transceiver compatibility, FIPS 140-2 SSL/TLS certification, and delivery of all bits on the wire to attached tools.
The IRS advanced Gigamon, Keysight, and Cisco Nexus Dashboard Data Broker for further consideration because those three vendors represented the strongest apparent alignment with the IRS requirement after initial market screening. Cisco was included because the IRS operates a substantial Cisco network environment, and Cisco Nexus Dashboard Data Broker warranted evaluation for potential interoperability with existing Cisco equipment, Nexus switching, and data center fabric architecture. The remaining fifteen vendors were screened out before final testing because they did not demonstrate all IRS essential must-have capabilities during initial review, as summarized below.
Vendor / Architecture
Not Advanced to Final Testing
NETSCOUT nGenius Packet Flow Switch
Arista DANZ Monitoring Fabric
Screening Result
Not advanced
Missing or Not Demonstrated Essential Must-Have Areas
Did not demonstrate full compliance with the IRS must-have matrix, including IRS-specific authentication/accessibility requirements, agent-based decryption, integrated cloud-environment support, and complete enterprise packet-delivery requirements.
Although reviewed as a market participant, it was not advanced because the screening record did not demonstrate full IRS must-have compliance for integrated cloud-environment support, IRS-specific authentication/accessibility requirements, FIPS/SSL-TLS requirements, and alignment with the existing Cisco-heavy IRS architecture.
APCON IntellaView / IntellaFlex
VIAVI packet broker / Observer-related offerings
Garland Technology TAP/NPB offerings
Network Critical SmartNA offerings
Did not demonstrate all IRS must-have requirements, including agent-based decryption, integrated cloud-environment support, IRS authentication/accessibility requirements, and full enterprise-scale centralized management requirements.
Market information did not demonstrate complete satisfaction of IRS must-haves, including enterprise-scale packet broker functions, agent-based decryption, PIV/SSO, integrated cloud support, and full IRS monitoring-tool delivery requirements.
Did not demonstrate all IRS must-have requirements for enterprise-scale packet brokering, including advanced decryption, centralized distributed management, integrated cloud-environment support, and full compliance with IRS authentication/accessibility requirements.
Did not demonstrate full IRS enterprise-scale capability;
market information reflected lower-capacity packet broker positioning and did not demonstrate all IRS must-haves for high-throughput enterprise operations, cloud integration, TO FAIR OPPORTUNITY
ACQUISITION TITLE: “Gigamon EOL & Expansion”
Treasury Standard Form – 1014 (Rev 12/24) agent-based decryption, and complete centralized management.
Cubro Packetmaster / Omnia
Did not demonstrate full satisfaction of IRS must-have requirements, including IRS-specific authentication/accessibility, agent-based decryption, integrated cloud-environment support, FIPS/SSL-TLS requirements, and complete enterprise operational integration.
cPacket Networks
Did not demonstrate complete compliance with the IRS must-have matrix, including agent-based decryption, IRS authentication/accessibility, FIPS/SSL-TLS requirements, and integrated enterprise/cloud management requirements.
Niagara Networks
Did not demonstrate full IRS must-have compliance during initial screening, including enterprise-scale distributed management, integrated cloud-environment support, agent-based decryption, and IRS authentication/accessibility requirements.
Profitap
Did not demonstrate all IRS essential must-have capabilities for enterprise packet brokering, including centralized distributed management, integrated cloud support, PIV/SSO, FIPS/SSL-TLS requirements, and agent-based decryption.
Datacom Systems
Did not demonstrate complete compliance with the IRS must-have matrix, including enterprise-scale management, cloud-environment support, agent-based decryption, PIV/SSO, and full packet-delivery requirements.
CGS Tower Networks
Did not demonstrate all IRS essential must-have requirements for enterprise-scale packet brokering, including advanced decryption, centralized management, cloud support, authentication/accessibility, and FIPS/SSL-TLS requirements.
Extreme Networks visibility/switching architecture
Not advanced because the architecture was identified as a switching/visibility solution that may function as a packet broker in certain designs, but did not demonstrate complete purpose-built compliance with IRS packet broker must-haves.
Juniper
Not advanced because the architecture was identified as a switching/visibility solution that may function as a packet broker in certain designs, but did not demonstrate complete compliance with the IRS packet broker must-have matrix.
Pluribus
Not advanced because the architecture was identified as a switching/visibility solution that may function as a packet broker in certain designs, but did not demonstrate all IRS essential must-have packet broker requirements.
TO FAIR OPPORTUNITY
ACQUISITION TITLE: “Gigamon EOL & Expansion”
Treasury Standard Form – 1014 (Rev 12/24)
Based on the IRS comparison, Gigamon met all must-have requirements. Keysight did not meet certain IRS must-have requirements, including government-certified
IPv6 compliance, ERSPAN aggregation support, and agent-based decryption. Cisco
Nexus Dashboard Data Broker did not meet certain IRS must-have requirements, including agent-based decryption and integrated cloud-environment capabilities comparable to on-premises functionality managed from the same central console.
Cisco also did not meet the should-have requirement for in-line decryption using pre-shared keys. These gaps are material because the IRS requires a packet broker solution that can support current and evolving enterprise security monitoring across on-premises and cloud environments while preserving visibility into encrypted and high-volume traffic flows.
Although Keysight and Cisco demonstrated packet broker functionality, neither solution satisfied the IRS’s full technical and operational requirements. Prior testing and engineering analysis showed that alternatives could meet basic functional needs in limited conditions but did not reliably sustain IRS production-scale traffic requirements. Cisco Nexus Dashboard Data Broker experienced technical limitations in extended production-scale testing, including issues forwarding traffic between separate physical switches in the stack and compatibility concerns that resulted in loss of critical cybersecurity analysis and reporting when used as a traffic source. Keysight demonstrated baseline packet broker capabilities but did not meet the broader IRS operational performance envelope due to gaps in scalability, packet processing efficiency, and application-layer visibility.
Because the evaluated solutions are proprietary commercial products, the IRS evaluated each product based on its currently available capabilities and did not require, request, or assume that a vendor would redesign its product, modify proprietary software, or add new features to satisfy unmet IRS requirements.
Vendor-driven redesign is outside the scope of the IRS evaluation process because the Government cannot reasonably estimate the cost, schedule, technical feasibility, or success of proprietary product changes that are controlled solely by the vendor and its internal development roadmap. Any attempt to rely on future vendor redesign would require additional market research, vendor engineering commitments, revised technical validation, and production-scale retesting, creating unacceptable schedule delay and operational risk. Accordingly, the IRS evaluated only currently available COTS capabilities and determined that alternatives with unmet must-have requirements could not be considered technically sufficient for this requirement.
Gigamon is therefore the only evaluated commercial off-the-shelf packet broker solution that satisfies the IRS’s full set of mandatory requirements within the required timeframe. Gigamon supports the IRS’s existing packet broker architecture, sustains enterprise-scale 40G/100G+ traffic loads, provides traffic aggregation, filtering, de-duplication, load balancing, metadata generation, SSL/TLS visibility, distributed management, and integration with existing CSIRC and NMCC monitoring tools. Continuing Gigamon support and expansion is necessary to replace end-of-life components, maintain vendor support, accommodate increased traffic volumes, and preserve cybersecurity visibility, monitoring, and operational reliability across the IRS enterprise.
TO FAIR OPPORTUNITY
ACQUISITION TITLE: “Gigamon EOL & Expansion”
Treasury Standard Form – 1014 (Rev 12/24)
Product Must Have
Should Have
Material Gaps
Gigamon 18 of 18 4 of 4 No identified gaps; met the full documented requirement set.
Keysight 15 of 18 3 of 4 Did not satisfy the IRS IPv6 requirement, ERSPAN aggregation, or agent-based pre-encryption visibility; did not provide the required level of
Application
Metadata
Intelligence.
Cisco
NDB
16 of 18 2 of 4 Did not satisfy agent-based pre-encryption visibility or integrated
AWS/Azure/
Google Cloud management;
did not provide pre-shared-key inline decryption or the required level of
Application
Metadata
Intelligence.
The IRS advanced Gigamon, Keysight, and Cisco Nexus Dashboard Data Broker for further consideration because those three vendors represented the strongest apparent alignment with th IRS requirement after initial market screening. Cisco was included because the IRS operates a substantial Cisco network environment, and Cisco Nexus Dashboard Data Broker warranted
TO FAIR OPPORTUNITY
ACQUISITION TITLE: “Gigamon EOL & Expansion”
Treasury Standard Form – 1014 (Rev 12/24) evaluation for potential center fabric architectur because they did not de summarized below.
Vendor / Architecture Not Advanced to
Final Testing interoperabi
e. The rema monstrate
Screening
Result lity with existing Cisco equipment, Nexus switching, and data ining fifteen vendors were screened out before final testing all IRS essential must-have capabilities during initial review, as
Missing or Not Demonstrated Essential Must-Have Areas
NETSCOUT nGenius Packet Flow Switch
Did not demonstrate full compliance with the IRS must-have matrix, including IRS-specific authentication/accessibility requirements, agent-based decryption, integrated cloud-environment support, and complete enterprise packet-delivery requirements.
Arista DANZ Monitoring Fabric
Although reviewed as a market participant, it was not advanced because the screening record did not demonstrate full IRS must-have compliance for integrated cloud-environment support, IRS-specific authentication/accessibility requirements, FIPS/SSL-TLS requirements, and alignment with the existing Cisco-heavy IRS architecture.
APCON IntellaView / IntellaFlex
Did not demonstrate all IRS must-have requirements, including agent-based decryption, integrated cloud-environment support, IRS authentication/accessibility requirements, and full enterprise-scale centralized management requirements.
VIAVI packet broker / Observer-related offerings
Market information did not demonstrate complete satisfaction of IRS must-haves, including enterprise-scale packet broker functions, agent-based decryption, PIV/SSO, integrated cloud support, and full IRS monitoring-tool delivery requirements.
Garland Technology TAP/NPB offerings
Did not demonstrate all IRS must-have requirements for enterprise-scale packet brokering, including advanced decryption, centralized distributed management, integrated cloud-environment support, and full compliance with IRS authentication/accessibility requirements.
Network Critical SmartNA offerings
Did not demonstrate full IRS enterprise-scale capability;
market information reflected lower-capacity packet broker positioning and did not demonstrate all IRS must-haves for high-throughput enterprise operations, cloud integration, agent-based decryption, and complete centralized management.
Cubro Packetmaster / Omnia
Did not demonstrate full satisfaction of IRS must-have requirements, including IRS-specific authentication/accessibility, agent-based decryption, integrated cloud-environment support, FIPS/SSL-TLS requirements, and complete enterprise operational
TO FAIR OPPORTUNITY
ACQUISITION TITLE: “Gigamon EOL & Expansion”
Treasury Standard Form – 1014 (Rev 12/24) cPacket Networks
Niagara Networks
Profitap
Datacom Systems
CGS Tower Networks
Extreme Networks integration.
Did not demonstrate complete compliance with the IRS must-have matrix, including agent-based decryption, IRS authentication/accessibility, FIPS/SSL-TLS requirements, and integrated enterprise/cloud management requirements.
Did not demonstrate full IRS must-have compliance during initial screening, including enterprise-scale distributed management, integrated cloud-environment support, agent-based decryption, and IRS authentication/accessibility requirements.
Did not demonstrate all IRS essential must-have capabilities for enterprise packet brokering, including centralized distributed management, integrated cloud support, PIV/SSO, FIPS/SSL-TLS requirements, and agent-based decryption.
Did not demonstrate complete compliance with the IRS must-have matrix, including enterprise-scale management, cloud-environment support, agent-based decryption, PIV/SSO, and full packet-delivery requirements.
Did not demonstrate all IRS essential must-have requirements for enterprise-scale packet brokering, including advanced decryption, centralized management, cloud support, authentication/accessibility, and FIPS/SSL- TLS requirements.
Not advanced because the architecture was identified as a switching/visibility solution that may function as a packet
Juniper
Pluribus architecture broker in certain designs, but did not demonstrate complete purpose-built compliance with IRS packet broker must-haves.
Not advanced because the architecture was identified as a switching/visibility solution that may function as a packet broker in certain designs, but did not demonstrate complete compliance with the IRS packet broker must-have matrix.
Not advanced because the architecture was identified as a switching/visibility solution that may function as a packet broker in certain designs, but did not demonstrate all IRS essential must-have packet broker requirements.
Based on the IRS comparison, Gigamon met all must-have requirements. Keysight did not meet certain IRS must-have requirements, including government-certified IPv6 compliance, ERSPAN aggregation support, and agent-based decryption. Cisco Nexus Dashboard Data Broker did not meet certain IRS must-have requirements, including agent-based decryption and integrated cloud-environment capabilities comparable to on-premises functionality managed from the same central console. Cisco also did not meet the should-have requirement for in-line decryption using pre-shared keys. These gaps are material because the IRS requires a packet broker solution that can support current and evolving enterprise security monitoring across on-premises and cloud
TO FAIR OPPORTUNITY
ACQUISITION TITLE: “Gigamon EOL & Expansion”
Treasury Standard Form – 1014 (Rev 12/24) environments while preserving visibility into encrypted and high-volume traffic flows.
Although Keysight and Cisco demonstrated packet broker functionality, neither solution satisfied the IRS’s full technical and operational requirements. Prior testing and engineering analysis showed that alternatives could meet basic functional needs in limited conditions but did not reliably sustain IRS production-scale traffic requirements. Cisco Nexus Dashboard Data Broker experienced technical limitations in extended production-scale testing, including issues forwarding traffic between separate physical switches in the stack and compatibility concerns that resulted in loss of critical cybersecurity analysis and reporting when used as a traffic source.
Keysight demonstrated baseline packet broker capabilities but did not meet the broader IRS operational performance envelope due to gaps in scalability, packet processing efficiency, and application-layer visibility.
Because the evaluated solutions are proprietary commercial products, the IRS evaluated each product based on its currently available capabilities and did not require, request, or assume that a vendor would redesign its product, modify proprietary software, or add new features to satisfy unmet IRS requirements.
Vendor-driven redesign is outside the scope of the IRS evaluation process because the Government cannot reasonably estimate the cost, schedule, technical feasibility, or success of proprietary product changes that are controlled solely by the vendor and its internal development roadmap. Any attempt to rely on future vendor redesign would require additional market research, vendor engineering commitments, revised technical validation, and production-scale retesting, creating unacceptable schedule delay and operational risk. Accordingly, the IRS evaluated only currently available COTS capabilities and determined that alternatives with unmet must-have requirements could not be considered technically sufficient for this requirement.
Gigamon is therefore the only evaluated commercial off-the-shelf packet broker solution that satisfies the IRS’s full set of mandatory requirements within the required timeframe. Gigamon supports the IRS’s existing packet broker architecture, sustains enterprise-scale 40G/100G+ traffic loads, provides traffic aggregation, filtering, de-duplication, load balancing, metadata generation, SSL/TLS visibility, distributed management, and integration with existing CSIRC and NMCC monitoring tools. Continuing Gigamon support and expansion is necessary to replace end-of-life components, maintain vendor support, accommodate increased traffic volumes, and preserve cybersecurity visibility, monitoring, and operational reliability across the IRS enterprise.
Product Must Have Should Have Material Gaps
Gigamon 18 of 18 4 of 4 No identified gaps; met the full documented requirement set.
Keysight 15 of 18 3 of 4 Did not satisfy the IRS IPv6 requirement, ERSPAN aggregation, or agent-based pre-encryption visibility; did not provide the required level of
Application Metadata
Intelligence.
Cisco NDB 16 of 18 2 of 4 Did not satisfy agent-based pre-encryption visibility or integrated
AWS/Azure/Google Cloud management; did not provide pre-shared-key inline decryption or the required level of
Application Metadata
Intelligence.
TO FAIR OPPORTUNITY
ACQUISITION TITLE: “Gigamon EOL & Expansion”
Treasury Standard Form – 1014 (Rev 12/24)
The Following 3 have been identified as the market leaders for Data Broker Solution. See table below:
Data Broker Market Leader Comparison
Requirement
Need
Gigamon
Keysight
Cisco Nexus
Dashboard
Data Broker
IPv6 Compliant - Can be remotely managed and perform data plane functions in an IPv6 network environment.
1 - Must Have
Meets
Does not meet (not govt
(certified for IPv6)
Section 508 Compliant -
Support most/all requirements for accessibility per s.508 and
IRM
Redundancy - Has backup or disaster recovery (DR) capability-built in.
PIV/SSO Compliant - Can authenticate application users based on IRS PIV card or related method e.g. SAML SSO.
(SAML or
TACACS
(TACACS+)
Aggregate traffic feeds (SPAN, tap, tunnel such as ERSPAN) meet (no
ERSPAN)
TO FAIR OPPORTUNITY
ACQUISITION TITLE: “Gigamon EOL & Expansion”
Treasury Standard Form – 1014 (Rev 12/24)
In-line decryption using PSK -store pre- shared keys to decrypt network traffic in flight for monitoring purposes
2 - Should
Does not meet
Agent-based decryption - ability to intercept packets from the network stack on an OS prior to encryption and forward to monitoring feeds meet
8 Output feeds to 3rd party tools 1 - Must Have Meets Meets Meets
Pre-built integrations w/Splunk
Output feeds - load balance to multiple ports for same tool
Allow filtering of traffic on inbound (tap/span) and outbound (tool connection) ports based on characteristics including MAC/IP/range, protocol/port, VLAN, and advanced network application detection.
TO FAIR OPPORTUNITY
ACQUISITION TITLE: “Gigamon EOL & Expansion”
Treasury Standard Form – 1014 (Rev 12/24)
Smart data processing -generate NetFlow based on packet data, de-duplicate packets in a feed, encapsulate / decapsulate packets, tunnel data to remote network location
Provide intelligent traffic detection and mapping (AMI) w/3000+ applications and 5000+ metadata attributes to assist in mapping traffic of interest to tools.
meet
Stack multiple chassis and stream traffic feeds over stack links to remote tool ports
Provide centralized management of all distributed chassis at local and remote sites
Provide integrated features comparable to on-prem in cloud environments incl AWS, Google, Azure and manage from same central console
TO FAIR OPPORTUNITY
ACQUISITION TITLE: “Gigamon EOL & Expansion”
Treasury Standard Form – 1014 (Rev 12/24) backplane max throughput specs - must run 10/40/100G at line rate d detect devices on tapped/spanned links using
CDP or LLDP or buffer packets at peak load (no packets dropped at line rate)
Rewrite MAC/VLAN in aggregated traffic streams to facilitate sorting/filtering and distribution to attached monitoring tools
Compatible with multiple transceiver vendors e.g. Cisco, Gigamon, Finisar, Approved
Optics etc.
FIPS140-2 SSL/TLS
Certification
Pass ALL bits on the wire to attached tools, not just IP traffic
IMPACT: This critical requirement for the IRS is to continue COTS Proprietary Gigamon services for Computer Security Incident Response Center (CSIRC) and Network Monitoring
Command Center (NMCC). If it is not completed, the voice & data communications infrastructure of the IRS will be seriously impacted with potential work stoppages and critical security risks that would impact daily operations and filing season. Gigamon’s product is peculiar to one manufacturer and contains proprietary technology, particularly in decryption an traffic intelligence, which no other vendor can replicate at the IRS’ required performance levels.
TO FAIR OPPORTUNITY
ACQUISITION TITLE: “Gigamon EOL & Expansion”
Treasury Standard Form – 1014 (Rev 12/24)
5. A determination that the anticipated cost to the Government will be fair and reasonable:
The Contracting Officer will determine the prices to be fair and reasonable. This requirement will also be competed amongst authorized resellers on the NASA SEWP V contract.
It is expected competition among authorized providers within NASA SEWP will result in a competitive price for the brand name item.
Award will be made to the lowest priced, technically acceptable (LPTA) offeror in accordance with the Independent Government Cost Estimate (IGCE) and adequate competition.
6.a Any other facts supporting this justification:
Gigamon is the only commercially available solution that meets the IRS’s operational performance and scalability requirements based on direct testing and engineering analysis.
While another solution initially appeared to meet minimum requirements, extended production-scale testing demonstrated that it could not scale to IRS traffic levels, resulting in unacceptable performance failures.
Accordingly, no other vendor provides a COTS solution that meets the IRS’s full set of technical and operational requirements, and building a custom solution is neither cost-effective nor timely.
In lieu of acquiring Gigamon software, IRS could potentially build a custom software solution to meet business need, but it will cost IRS significantly more and much longer to build that solution in house for the business requirements of Cybersecurity business unit.
6.b Attachments: □ Yes � No Acq Plan, IGCE and SOW
7. A statement of the actions, if any, the Requiring Activity and Contracting Activity may take to remove or overcome any barriers that led to the exception to fair opportunity before any subsequent acquisition for the supplies and services is made:
This requirement is a proprietary based brand name acquisition and only limited sources, in addition to manufacturer, are available and authorized to provide these items. For any subsequent acquisition for similar supplies, the IRS will attempt to remove barriers to competition to the maximum extent practicable. The Government will continue to search the marketplace for other software products by participating in industry days and consulting trade publications to determine whether they meet the Government’s needs. Every opportunity will be taken to ensure that fair opportunity is achieved and that future Gigamon procurements of this requirement (if required) are competitively solicited to the maximum extent practicable.
8. Certifications and Approvals:
8.a Program Office Certification (Requiring Activity). I hereby certify that any supporting information and data provided (e.g., the Government’s minimum needs or requirements, or other rationale for the limited sources) and which form the basis for this justification for an exception to fair opportunity, are accurate and complete to the best of my knowledge and belief.
TO FAIR OPPORTUNITY
ACQUISITION TITLE: “Gigamon EOL & Expansion”
Treasury Standard Form – 1014 (Rev 12/24)
Name: William Ramirez-Castro Date:
Signature:
William R. Ramirez-Castro Digitally signed by William R. Ramirez-Castro
Date: 2026.07.22 16:04:55 -04'00'
8.b Contracting Officer Certification and Approval. I certify this justification for an exception to fair opportunity is accurate and complete to the best of my knowledge and belief.
Therefore, unless additional approvals are required as prescribed below, as the authorized contracting officer for this acquisition, I hereby approve the processing of this requirement based on the authority specified in 4.a above.
Name: Fatima Paen Date:
Signature:
Fatima A. Paen
Digitally signed by Fatima A. Paen
Date: 2026.07.22 16:29:18 -04'00'
9. Additional Reviews and Approvals (As applicable):
9.a Bureau Chief Information Officer or Authorized Designee (for IT requirements that are over $5 million, but not exceeding $90 million) (Contracting Activity). I have reviewed this justification and find it to be accurate and complete to the best of my knowledge and belief, and representative of the Government’s need. Therefore, I hereby consent to the approval of this justification. (Note: The Bureau CIO may delegate their authority for proposed contracts over $5 million, but not exceeding $15 million to the Associate Bureau CIO(s).)
Name: Kaschit Pandya, Chief Information Officer, IRS Date:
Signature:
9.b Advocate for Competition (if over $900,000, but not exceeding $20 million)
(Contracting Activity). I have reviewed this justification for an exception to fair opportunity and find it to be accurate and complete to the best of my knowledge and belief. Therefore, unless additional approvals are required as prescribed below, as the ordering activity’s
Advocate for competition, I hereby approve this justification based on the authority specified in 4.a above.
Name: Julius Bradshaw Date:
8/4/2026
Signature: Julius S. Bradshaw Date: 2026.08.04 12:07:51 -04'00' Digitally signed by Julius S. Bradshaw
9.c Head of the Procuring Activity or Authorized Designee (if over $20 million, but not exceeding $90 million) (Contracting Activity). I have reviewed this justification for an exception to fair opportunity and find it to be accurate and complete to the best of my knowledge and belief. Therefore, unless additional approvals are required as prescribed below, as the head of the procuring activity or authorized designee, I hereby approve this justification based on the authority specified in 4.a above.
TO FAIR OPPORTUNITY
ACQUISITION TITLE: “Gigamon EOL & Expansion”
Treasury Standard Form – 1014 (Rev 12/24)
Name: Date:
9.d Treasury Chief Information Officer (for IT requirements that are over $90 million). I have reviewed this justification and find it to be accurate and complete to the best of my knowledge and belief, and representative of the Government’s need. Therefore, I hereby consent to the approval of this justification.
Name: Date:
Signature:
9.e Senior Procurement Executive (if over $90 million) (Contracting Activity). I have reviewed this justification for an exception to fair opportunity and find it to be accurate and complete to the best of my knowledge and belief. Therefore, as the senior procurement executive, I hereby approve this justification based on the authority specified in 4.a above.
Name: Date:
File details come from the government source that posted it. Updated .