A02 TAB B - Palantir EA Final JA 03JUL2025 v2_Redacted.pdf

Control Number: JA-25-Rock Island/EIS-0423

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Justification Review Document for Other than Full and Open Competition - FAR Part 6

Program/Equipment: Enterprise Agreement (EA) for a Justification for the consolidation of Palantir USG, Inc’s (herein referred to as Palantir) current and future commercial solutions, including core software, data, compute infrastructure, and ancillary support services, such as software modifications, auxiliary modules, engineering services, field service representatives (FSRs), training, enablement services, and hardware for the Headquarters Department of the Army, Office of Chief Information Officer (HQDA OCIO).

Authority: 10 U.S.C. 3204(a)(1) as implemented by FAR Part 6.302-1(a)(2) -- Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements.

Amount:

Prepared by:

Typed Name: Mrs. Maria C. Vital-Smith DSN: 520-693-0046 Title: Contract Specialist Date: 22 April 2025 E-mail: maria.c.vital-smith.civ@army.mil

Contracting Officer:

Typed Name: Mr. Benjamin L. Geringer DSN: 571-588-8567 Date Reviewed: 23 April 2025 E-Mail: benjamin.l.geringer.civ@army.mil

Controlled By: HQDA OCIO CUI Categories: PROCURE / SSEL Limited Dissemination: FEDCON

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Reviews

I have reviewed this justification and find it adequate to support other than full and open competition.

Command Advocate for Competition

Typed Name: Mr. Jason E. VanLuven DSN: 520-671-3284

Signature: _________________________________ Date: ______________________

VANLUVEN.JASON.

E.1288547374

Digitally signed by

VANLUVEN.JASON.E.1288547374

Date: 2025.06.23 15:03:51 -04'00' 23 JUN 2025

Justification and Approval for Other than Full and Open Competition – FAR Part 6

1. Contracting Activity: U.S. Army Contracting Command – Rock Island (ACC-RI) Rock Island Arsenal, Rock Island, IL 61299-8000, Strategic Information Technology (IT) Division operating under Army Contracting Command – Aberdeen Proving Ground (ACC-APG) Senior Contracting Official’s authority.

2. Description of Action: Headquarters Department of the Army, Office of Chief Information Officer (HQDA OCIO) requests a new Enterprise Agreement (EA) for a

Single Award (SA) Indefinite Delivery Indefinite Quantity (IDIQ) contract to include a This proposed EA will be awarded to Palantir (635 Waverley St. Palo Alto, CA 94301-2550; Cage 51W88).

The contract type is Firm-Fixed-Price (FFP) contract line-item numbers (CLINs). This EA will cover a catalog offering of Palantir’s current and future commercial solutions, including core software, data, compute infrastructure, and ancillary support services, such as software modifications, auxiliary modules, engineering services, field service representatives (FSRs), training, enablement services, and hardware. This EA is critical to HQDA OCIO’s ability to streamline procurement and significantly lower administrative costs associated with acquiring Palantir’s products and services. ACC-RI projects award of this IDIQ for . Multiple types of funding will be used and are to be determined at the order level. The total ceiling is .

In accordance with (IAW) Defense Federal Regulation Supplement 207.103(d)(i)(B), the required acquisition plan will route with this Justification and Approval (J&A) to the Senior Procurement Executive.

3. Description of Supplies/Services: This EA is for the consolidation of Palantir’s current and future commercial solutions, including core software, data, compute infrastructure, and ancillary support services, such as software modifications, auxiliary modules, engineering services, FSRs, training, enablement services, and hardware. The proposed EA represents the most cost-effective and efficient solution to address administrative, financial, and operational costs and establish a single IDIQ contract vehicle for all future needs, avoiding the complexities and overhead of multiple individual contracts. The planned EA is for , which includes a

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This EA will include previous competitively awarded solutions (see Table 1 below) and will build on existing capabilities servicing Army programs. The Army has determined that Palantir's Federal Cloud Service (PFCS) environment platform represents a uniquely integrated solution essential to ongoing operations. PFCS is proprietary. PFCS enables users to ingest, manage, search, transform, analyze, and present data in a variety of ways depending on their needs and technical proficiency. Alternative vendors lack Palantir’s comprehensive integration with existing Army systems, its specifically tailored data ontology, and its validated operational performance. Therefore, a sole-source award to Palantir is justified as the only viable option to ensure continuity of operations and minimize risk to the warfighter.

The Palantir Platform, providing advanced capabilities in Artificial Intelligence/Machine Learning (AI/ML), data integration, operational planning tools, and secure cloud services, is currently deployed and actively utilized under competitively awarded contracts representing key Army priorities. These contracts, detailed in Table 1 below, demonstrate the Army’s existing investment in and reliance on Palantir’s commercial solutions across a diverse range of operational requirements. This EA is designed to consolidate and streamline these existing efforts.

Table 1

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The diverse configurations of the Palantir Platform detailed in Table 1 - encompassing advanced AI/ML capabilities, data integration, operational planning tools, and secure cloud services - consistently operate across classified and unclassified environments (IL2, IL4, IL5, IL6) with existing Defense Information Systems Agency (DISA) Provisional Authorizations (PAs). This consistent security posture is enabled by leveraging the PFCS and Software as a Service (SaaS) offering, which are already accredited to meet stringent security requirements. In alignment with Army Directive 2024-02 and ASA(ALT) Software Bill of Materials Policy (07 October 2024), all cloud-based software capabilities supporting mission-critical functions must operate within secure, accredited environments that comply with the DISA Cloud Computing Security Requirements Guide (SRG) (30 January 2025) and DoD Instruction 8500.01 “Cybersecurity” (14 March 2014). These policies require that cloud services handling Controlled Unclassified Information, National Security Systems data, and classified information must operate at designated ILs (IL4, IL5, and IL6), based on data sensitivity and mission requirements. As further explained in Section 5, Palantir platform’s existing accreditations ensure compliance with these policies, eliminating the need for duplicative efforts and costly delays associated with transitioning to a new vendor.

This requirement is for mission-critical capabilities, including real-time data fusion, operational planning, logistics optimization, and intelligence analysis, all delivered within secure, accredited environments spanning FedRAMP High / Impact Level (IL)-2, IL4, IL5, and IL6 network environments in addition to Army intelligence networks and Army mission partner environments.

The EA includes the key components summarized below, which provide a high-level overview of the items being procured; however, Attachment 01 to this document contains a detailed and comprehensive description of the components and their specific functionalities.

Network Infrastructure Licenses – This license type enables access for users within defined license holder groups on a specified network through a Network Infrastructure License.

Base Capability Licenses – Provides access to core software capabilities for unlimited end-users within a defined user group

Evaluation Licenses – Grants full functionality of a Base License capability for up to days on a specified network with user account limits.

Adjacent Capability Module – A license for pre-configured software modules that extend or enhance the functionality of Base or Evaluation Licenses.

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Edge Capability Licenses – A license type tied to hardware-centric, edge-based software solutions designed for tactical and disconnected environments.

Engineering Services – Technical support for deployment, integration, and optimization.

Field Service Representatives – On-site engagement services for testing, troubleshooting R&D capabilities, user feedback collection, and training support.

Exercise Support Services – SME support for field exercise planning and execution.

Training – "Train the trainer" courses for New Equipment Training (NET) or operational units.

The Independent Government Estimate (IGE) for the is summarized below:

The IGE for Palantir’s commercial solutions was derived based on historical spending patterns observed across previously competed contracts, as detailed in Table 1 above. These contracts collectively represent the Army’s expenditures on Palantir’s advanced AI/ML capabilities, data integration tools, operational planning software, and secure cloud services. Over , the Army’s annual spending on these solutions has demonstrated a consistent upward trajectory, culminating in an annual cost estimate of approximately . The IGE assumes steady annual costs over a

, resulting in a total estimate cost of . This projection is based on the Army’s current and anticipated usage of Palantir’s solutions, as well as the vendor’s ability to deliver consistent performance and compliance with security requirements, including FedRAMP High and DoD Impact Levels (IL4, IL5, and IL6).

4. Authority Cited: 10 U.S.C. 3204(a)(1) as implemented by FAR Part 6.302-1(a)(2) -- Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements.

5. Reason for Authority Cited: Palantir is the only vendor capable of providing the required capabilities in Section 3 above without unacceptable delays, significant duplication of effort, and costs to the Government. HQDA OCIO and its subordinate Project Management Offices along with Program Executive Office (PEO) Enterprise have made significant investments in Palantir’s commercial solutions, integrating Palantir’s platform extensively across the Army’s operational environment. Over

Army personnel are currently proficient in its use, highlighting its deep integration into Army operations and reflecting a fundamental shift in how the Army processes information and executes missions. This integration extends beyond mere software adoption. It encompasses a uniquely tailored operational framework developed over years of collaborative effort with Warfighters. Replacing Palantir’s proprietary platform would necessitate a complete rebuilding of this framework, including data re-

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normalization, system integration, and extensive personnel retraining. Due to the specialized nature of this integration and the Army’s substantial investment, no other vendor possesses the equivalent capability or could realistically deliver a comparable solution within . Achieving the necessary accreditations for FedRAMP High, DoD Impact Levels (IL)-2, IL-4, IL-5, and IL-6, as well as Army intelligence networks like JWICS and mission partner environments such as CENTRIX, BICES, and MPN, would require a new contractor to invest significant time and resources. Specifically, accreditation efforts for another vendor could result in duplicative costs ranging from

, which the Government could not reasonably expect to recover through competition. Furthermore, this process would introduce substantial delays, requiring to for accreditation and system rebuilds, leading to unacceptable operational disruption, a duplicative effort, and a significant impact on mission effectiveness and ongoing operations. Additionally, the competitive procurement process and subsequent system rebuild would result in unacceptable operational disruption and a , duplicative effort, ultimately hindering mission effectiveness and jeopardizing ongoing operations. The agency is consolidating supplies and services that were previously competed and awarded under different contracts into a single Indefinite Delivery/Indefinite Quantity (IDIQ) EA contract. This EA will provide efficient ordering methods and negotiated discount rates, reflecting the Army’s comprehensive adoption of Palantir’s platform. This consolidated approach is critical to maximizing the return on the Army’s investment and is not achievable through individual contracts.

Palantir satisfies the following compliance frameworks which are part of the overall Palantir platform solution:

SSAE 18/ISAE 3000 Service Organization Control (SOC):

SOC 1, Type 2 (Computer Operations, Information Security, Change Control, Data Communications) SOC 2, Type 2 (Security, Confidentiality, and Availability)

SOC 3

International Organization for Standardization (ISO), including but not limited to:

ISO 27001

ISO 27017

ISO 27018

ISO 9001

NIST 800-53 and NIST 800-171, including control sets for the following baselines:

FedRAMP High FISMA High Impact Level 2 DoD SRG Impact Level 5 DoD SRG Impact Level 6 DoD SRG

CMMC

Other compliance frameworks, including:

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Cyber Essentials Plus NCSC Cloud Security Principles NHS Digital Data Security and Protection Toolkit

GDPR

Web Content Accessibility Guidelines (WCAG) 2.1 and Section

Specific regulatory and industry requirements

SOC 1 / ISAE 3402

GxP

CCPA

CJIS

HIPAA

ITAR

Procuring these commercial solutions using separate contracts requires significant administrative time and resources. This approach is inefficient and can result in delays, with prior procurement history for similar efforts indicating timelines of to complete. While efforts are underway to streamline processes and reduce timelines in the current environment, the complexity of requirements, coordination across stakeholders, and the accreditation processes involved remain key factors that can impact the speed of execution. Using a single comprehensive IDIQ contract will allow the agency to manage the procurement more effectively and efficiently, ensuring timely delivery of critical supplies and services. Combining these contracts is expected to result in substantial cost savings for the Army as explained below. Replicating Palantir's uniquely accredited and integrated platform through a new competition would be exceptionally challenging and time-consuming. Ensuring continuity of operations is critical and this EA will allow all DoD Departments and Agencies to have access to the consolidated EA items, leveraging Palantir’s existing support of agency’s requirements, systems, and processes to ensure a seamless transition and uninterrupted delivery of supplies and services. Introducing a new contractor would require a significant ramp-up period, ranging from an estimated for simple projects to up to for highly complex projects requiring accreditation, The Army’s spending and user growth for the Palantir Platform continue to accelerate.

expenditures on Palantir’s commercial solutions have consistently increased at an annual rate exceeding . Based on historical spending patterns, which have demonstrated a stable upward trajectory over multiple fiscal years, it is projected that spending will surpass . This sustained growth reflects a reliable and continuous increase, underscoring the Army’s growing dependence on the Palantir Platform to address evolving mission requirements across enterprise business functions and all warfighting domains, including command and control, targeting and fires, sustainment, intelligence, protection, and cyber operations.

Without the EA, the projected Army obligations are outlined below:

i. Estimated existing contract obligations:

o

ii. Projected annual growth of obligations:

o

This anticipated growth will require increased annual obligations across Army programs This EA offers a cost-effective alternative, maintaining the ceiling at

By establishing this EA with Palantir, the Government can avoid fragmented contracting efforts, increase efficiencies, and ensure transparency, cost efficiency, scalability, and rapid access to Palantir’s capabilities with maximal purchasing power.

HQDA OCIO market research has found in historical contract data that the Army’s Palantir platform deployment has undergone extensive customization and integration of critical data sources, creating a highly specialized and interdependent environment. A transition to another vendor would require a complete rebuilding of the platform environment, a complex data migration, and a significant loss of institutional knowledge.

The administrative costs and risks associated with this transition are unacceptable, as the complexity of re-establishing seamless data integration, operational workflows, and mission-critical capabilities would directly impact the warfighter. Specifically, this disruption would result in delays in accessing critical intelligence and operational data, reduced situational awareness, and interruptions in mission planning and execution.

Warfighters would face increased risks in the field due to gaps in real-time information and decision-making tools. Additionally, the loss of institutional knowledge would hinder the Army’s ability to maintain operational continuity, further degrading readiness and

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effectiveness. HQDA OCIO also considered the possibility of utilizing existing contract vehicles for other solutions. However, only Palantir can directly provide the full suite of their commercial solutions while meeting active provisional authorizations across all relevant impact levels. The proposed EA will deliver significant reduced administrative costs associated with procurement. While Palantir-related action in FY25 involved approximately 75 active contracts supported by the Army acquisition workforce, the EA scope focuses on the 15 relevant and active contracts under this new vehicle. Based on Government historical contract administration data, each modification currently requires an average of 15 hours of review and approval time involving four to five Government personnel. With these 15 contracts requiring an average of one to two modifications per year, streamlining under an EA could reduce cumulative review time by over 338 hours annually (15 contracts x 1.5 modifications x 15 hours = 338 hours), freeing critical acquisition workforce capacity for higher-value activities. This streamlined approach not only reduces administrative overhead but also accelerates access to critical capabilities, driving procurement efficiency through economies of scale and enabling the Army to refocus personnel efforts on higher priority operational needs.

The graph above illustrates the comparison of contracted dollars between Army and non-Army contracts. This EA will incorporate the commercial solutions utilized in non- Army contracts, provide enhanced visibility and offer all DoD the benefit of a pre-priced, consolidated procurement vehicle.

The EA will allow a streamlined consolidated option by simplifying the ordering process through a single IDIQ vehicle. The Government will have improved visibility and

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comprehensive tracking of spending with Palantir. Consolidation of products and services will have a faster lead time due to pre-negotiated terms and conditions.

Therefore, a sole source procurement is necessary to ensure continuity of critical mission capabilities.

Throughout the DoD, this EA will drive accountability, achieve administrative cost savings, and reduce procurement manpower by replacing the current process of purchasing and executing separate contracts of the same products or services.

This IDIQ structure will allow all authorized users in DoD Departments to easily order products and services from a pre-approved catalog at pre-negotiated prices, significantly reducing the administrative burden.

Establishing this EA will provide a streamlined, consolidated procurement vehicle that ensures the Army is able to measure programmatic metrics while having transparency, cost efficiency, scalability, and rapid access to Palantir’s capabilities with maximal purchasing power

In summary, the Army has determined that transitioning from Palantir’s deeply integrated solution to another vendor would introduce unacceptable operational risk and significant administrative costs. Maintaining the current deployment ensures continuity of critical mission capabilities and avoids the disruption associated with competitive procurement and subsequent system re-architecture. This strategy, which involves integrating previously competed contracts, aims to reduce the costs and achieve greater efficiency. This EA will streamline operations, eliminate unnecessary pass-through costs, and enhance overall cost effectiveness. Due to the Army’s deep integration with Palantir’s proprietary platform, only Palantir can provide the full suite of required solutions while maintaining current active provisional authorizations across all relevant impact levels. Transitioning to an alternative vendor would necessitate a complete re-architecture of existing systems and platforms and a lengthy, costly, and potentially unsuccessful re-authorization process, introducing unacceptable delays

6. Efforts to Obtain Competition: IAW FAR 5.201, ACC-RI will synopsize this action.

a. Effective competition. Because this is a sole source action, effective competition is not available. A Sources Sought was posted to SAM.GOV on .Responses were due No responses were received from vendors demonstrating the capability to fulfill the Government’s needs. Further details can be found in Section 8 “Market Research” below.

b. Subcontracting competition. As part of any contract awarded as the result of this J&A, the prime contractor shall provide to the Government, in accordance with FAR 52.219-9, Small Business Subcontracting Plan, and FAR Subpart 9.6, Contractor Team Arrangements, for Government review and approval. The contract will include any required subcontracting competition clauses such as FAR 52.219-8, Utilization

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of Small Business Concerns and FAR 52.244-5, Competition in Subcontracting.

7. Actions to Increase Competition: HQDA OCIO will continue to actively monitor the commercial marketplace for potential alternatives, including other commercial solution providers and any future authorized distributors for commercial solutions. This includes core software, data, compute infrastructure, and ancillary support services, such as software modifications, auxiliary modules, engineering services, FSRs, training, enablement services, and hardware. The intent of this EA is to streamline access to Palantir’s existing commercial solutions while ensuring the Government retains the ability to solicit competitive proposals for future programs and requirements. Any decision to switch to a competitor's platform will be carefully evaluated based on the Army’s capability requirements, DoD approval, and the potential benefits and costs, including the risks of operational disruption, retraining, and recertification. This EA does not substitute competition for future programs and is not intended to unduly restrict the Government’s ability to pursue competitive acquisitions in the future. This EA is designed to streamline access to Palantir’s existing commercial solutions.

The Army will continuously evaluate emerging capabilities and reassess this consolidation every to ensure ongoing improvements, optimal performance, and encourage constant innovation and competition in the market (Army Open Solicitation https://sam.gov/opp/20f6ad25a7c64be891ca8a24fa9b452b/view).

Only Palantir can directly provide the full suite of their commercial solutions while meeting active provisional authorizations across all relevant impact levels. The EA is designed to streamline access to Palantir’s existing commercial solutions.

8. Market Research:

A Sources Sought was posted to SAM.GOV on .Responses were due

. No responses were received from vendors demonstrating their capability to fulfill the Government’s needs.

Each vendor was evaluated against the Army’s key requirements outlined in Section 3, which include comprehensive accreditation across all Impact Levels (IL2-IL6), seamless integration with tactical data links and mission partner environments, support for Generative AI (GenAI) capabilities on classified networks, and existing data integration with hundreds of Joint and Army systems. The evaluation process demonstrated that

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none of the responding vendors, except Palantir, possess the unique combination of capabilities required to meet the Army’s operational needs.

Market research conducted between that responded to the solicitation:

Each vendor was evaluated against the Army’s key requirements outlined in Section 3, which include comprehensive accreditation across all Impact Levels (IL2-IL6), seamless integration with tactical data links and mission partner environments, support for Generative AI (GenAI) capabilities on classified networks, and existing data integration with hundreds of Joint and Army systems. The evaluation process demonstrated that none of the responding vendors, except Palantir, possess the unique combination of capabilities required to meet the Army’s operational needs.

Evaluation Results:

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Palantir’s Unique Capabilities: The Army has determined that Palantir's Federal Cloud Service (PFCS) environment platform represents a uniquely integrated solution essential to ongoing operations. PFCS is proprietary and enables users to ingest, manage, search, transform, analyze, and present data in a variety of ways depending on their needs and technical proficiency. Palantir is the only vendor that meets all the Army’s requirements as outlined in Section 3:

Comprehensive Accreditation: Palantir is uniquely authorized across all Impact Levels (IL2-IL6), ensuring seamless support for unclassified, sensitive, and classified workloads.

GenAI Capabilities: Palantir provides Generative AI capabilities on all classified networks, enabling advanced data analysis and decision-making directly integrated into Army Warfighting missions.

Integration with Tactical Data Links: Palantir offers seamless integration into tactical data links and mission partner environments, supporting battlefield applications such as C2, intelligence fusion, targeting, and fires.

Tailored Data Ontology: Palantir’s specifically tailored data ontology supports real-time data fusion, operational planning, logistics optimization, and intelligence analysis.

Validated Operational Performance: Palantir has demonstrated consistent performance and compliance with security requirements, including FedRAMP High and DoD Impact Levels (IL4, IL5, and IL6).

Conclusion: The evaluation process confirmed that none of the responding vendors, except Palantir, can meet the Army’s requirements as outlined in Section 3. This determination is based on a thorough comparison of vendor capabilities and is supported by evidence from DISA’s official listings and the Army’s operational requirements. Palantir’s unique combination of capabilities, accreditations, and integrations makes it the only vendor capable of supporting this consolidation effort without introducing unacceptable risks or disruptions to Army operations.

In alignment with FAR Part 10, the Government conducted market research encompassing a wide range of commercial data analytics and intelligence solutions to ensure this acquisition meets mission requirements. This included reviewing findings from over active contracts, some of which involved the Palantir Platform, alongside independent analysis of vendor capabilities and market trends. FAR Part 10.002(b)(1) emphasizes the use of previously conducted market research where it is relevant and applicable, and accordingly, the Government has specifically focused on separate market research efforts conducted within of this action. The historical data and findings from these contracts have consistently highlighted that the Palantir commercial Platform is the only viable solution capable of meeting the Government's critical needs for data integration, analytics, and security at the enterprise level without degradation to Warfighter operations. By utilizing this existing body of market research, the Government ensures compliance with FAR Part 10 requirements while avoiding redundancy and unnecessary expenditure of resources. Given the proprietary nature of the Palantir Platform and the Army’s existing deep integration with its capabilities, a

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comprehensive new market research effort was deemed unlikely to identify viable alternative solutions. However, existing market analyses were reviewed to confirm the continued relevance and cost-effectiveness of the Palantir Platform.

This action is justified by the Army’s significant investment in and integration with the proprietary Palantir Platform, which has been established through multiple competitive awards, as detailed in Table 1. As part of these competitive actions, the Army conducted market research in compliance with FAR Part 10, identifying vendors in the marketplace. These efforts included technical capability assessments and pricing validation to ensure fair and open competition. Across the competed contracts detailed in Table 1, Palantir consistently emerged as the most qualified vendor due to its unique combination of advanced data integration, analytics capabilities, and adherence to stringent security standards required for national security operations. The Army’s market research and competitive evaluations demonstrate that Palantir’s solutions are uniquely positioned to meet mission requirements without compromising operational continuity or security.

9. Interested Sources: As described above, the following sources have written to express interest:

10. Other Facts:

a. Procurement history. While HQDA OCIO and the Army have previously acquired individual components of the Palantir ecosystem – including core software, data, compute infrastructure, and associated support services – through full and open competition, this procurement represents a fundamentally new requirement: the consolidation of these previously disparate elements (as outlined in Table 1) into a unified, integrated solution for Palantir’s commercial solutions.

This EA will cover all future actions for all Palantir commercial services Attachment 01 – Palantir EA Commercial Solutions List. Each action will be supported by a memorandum for record stating the action is within the scope of this EA J&A in each contract file.

b. Other facts. The Government maintains unlimited rights and ownership to all Government data, documents, transformations involving manipulation of Government data. Government data means individual facts, statistics, personal information (e.g. PII or PHI)) or items of information that are expressed as quantities, characters, images, or

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symbols on which operations are performed by a computer; being stored and transmitted in the form of electrical signals and recorded on any physical media provided by the Government, Government authorized user, or a third party for entry, storage, or transmission in Government systems, including any such data that is inputted by Government Authorized Users, or located in any data files, tables, objects, or any storage medium developed or maintained by the KTR, including data that is an improvement, modification, adaptation, translation, or derivation of the Government Data. Government Data does not include base Client Software, that is not utilized to transform Government data and the Software as a Service and/or any other contractor commercial software solutions. Any access to the contractor’s commercial software is subject to contractor’s License and Service Agreement.

All rights, titles, and interest in Government Customer Data (as defined below) will remain the property of the Government. The Contractor/Licensor has no intellectual property rights or other claims to Customer Data that is hosted, stored, or transferred to and from the Products or the cloud services platform provided by the Contractor/Licensor, or to the Customer’s Confidential Information and personally identifiable information.

Definition of Customer Data:

Government "Customer Data" includes any data, text, drawings, diagrams, images, or sounds (together with any database made up of any of these and/ or any data derivatives i.e. Models, weights, etc.) which are embodied in any electronic, magnetic, optical, or tangible media. This includes any Customer's Confidential Information and any personally identifiable information relating to any customers, end users, or employees of the Customer, its suppliers, or contractors ("Personal Data"), to which the Contractor/Licensor has or may have access in connection with the operation or administration of the Contractor/Licensor's platform, or in connection with the performance of Professional Services by the Contractor/Licensor for the Customer under this contract or any applicable performance work statements. Customer Data also includes any data that is commingled with and/or modified by third-party data sets, applications, machine learning, artificial intelligence, and/or analytics tools. All generated or enhanced data sets are considered "Customer Data".

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11. Technical Certification:

12. Requirements Certification:

13. Fair and Reasonable Cost Determination:

I hereby determine that the anticipated cost to the Government for this contract action will be fair and reasonable. Price analysis, such as comparison to previous prices paid, published pricing, and the IGE will be used to determine the price to be fair and reasonable in accordance with FAR 15.4. Certified cost and pricing is not required as the products and related incidental services being acquired are commercial items and services IAW FAR 15.403-1(c)(3).

Signature: ________________________________Date: ______________________

Typed Name: Mr. Benjamin L. Geringer Title: Contracting Officer

14. Contracting Officer Certification:

I certify that this justification is accurate and complete to the best of my knowledge and belief.

Signature: ________________________________Date: _______________________

Typed Name: Mr. Benjamin L. Geringer Title: Contracting Officer

GERINGER.BENJAMIN

.L.1387649154

Digitally signed by

GERINGER.BENJAMIN.L.1387649154

Date: 2025.06.17 14:05:23 -05'00' 17 JUN 2025

GERINGER.BENJAMIN

.L.1387649154

Digitally signed by

GERINGER.BENJAMIN.L.1387649154

Date: 2025.06.17 14:05:43 -05'00' 17 JUN 2025