Brand Name Justification - Axon Sky Hero Redacted_Redacted.pdf

United States Department of Justice United States Marshals Service

FAR Overhaul Part 6 JOFOC for FY26 TD AXON SKY-HERO 15M10426QA470008

Revision dated 10 April 2026

Justification for Other Than Full and Open Competition (FAR Overhaul Part 6) This justification is prepared in accordance with FAR Overhaul Part 6. This acquisition is conducted as a commercial acquisition in accordance with FAR Overhaul Part 12.

Contracting Office Training Division (TD)

MIQ Request Number

Contract Specialist / Officer Name Christopher Jones

Contracting Officer’s Representative

Description of Supply or Service

This acquisition is for the purchase of commercial, brand-name Axon Sky-Hero products to include the Axon Sigyn MKL ground tactical robot to support the operational requirements of the United States Marshals Service (USMS), Training Division (TD) and various other divisions and districts. The requirement includes commercially available tactical ground robots and accessories necessary to provide an integrated, interoperable system capable of detecting, identifying, tracking, monitoring, and supporting responses to the apprehension of fugitives by providing real time reconnaissance. The robots that are the subject of this Justification provide relevant USMS tactical requirements, including range, mobility, agility and durability.

The acquisition will be conducted as a commercial supply procurement using FAR Overhaul Part 12 procedures and a Firm-Fixed-Price (FFP) contract.

Nature or Description of Action

This acquisition is a new commercial supply procurement for the purchase of brand-name Axon Sky-Hero products to support the operational requirements of USMS TD, as well as various other divisions and districts. The procurement will be conducted using FAR Overhaul Part 12 commercial acquisition procedures and will result in the award of a FFP contract.

The acquisition is a stand-alone open market procurement and is not an order under an Indefinite-

FAR Overhaul Part 6 JOFOC for FY26 TD AXON SKY-HERO 15M10426QA470008

Revision dated 10 April 2026

Delivery/Indefinite-Quantity (IDIQ) contract, Blanket Purchase Agreement (BPA), or Federal Supply Schedule

(FSS).

Because the Government's minimum requirements necessitate the Axon Sky-Hero ecosystem, this acquisition utilizes a brand-name specification in accordance with FAR Overhaul 6.103-1(d).

Vendor’s / Brand Name

Brand Name: Axon Sky-Hero

The Government's requirement is for the Axon Sky-Hero products, and will be posted on the Government-Wide Point of Entry (sam.gov).

Estimated Total Value

Indicate Statutory Authority for Contracting without Full and Open

Competition

The authority for contracting without full and open competition is identified below in accordance with FAR Overhaul Part 6.103-1 through 6.103-7. Select one:

Only one responsible source and no other supplies or services will satisfy agency requirements.

Unusual and compelling urgency.

Industrial mobilization; engineering, developmental, or research capability; or expert services.

International agreement.

Authorized or required by statute.

National security.

Public interest.

OR

The requirement includes brand-name specifications or features peculiar to one manufacturer in accordance with FAR Overhaul 6.103-1(d).

Contractor’s Unique Qualifications or Basis for Limiting Competition

The Government's minimum requirement is for commercially available, fully integrated ground tactical robots and accessories necessary to provide an integrated, interoperable system capable of detecting, identifying, tracking, monitoring, and supporting responses to the apprehension of fugitives by providing real time reconnaissance. The robots provide tactical structure needed to include range, mobility, agility and durability.

The required capability must provide seamless interoperability among other equipment USMS has

FAR Overhaul Part 6 JOFOC for FY26 TD AXON SKY-HERO 15M10426QA470008

Revision dated 10 April 2026 available to them to include Axon Loki Drones and other equipment.

Market research determined that the Axon Sky-Hero uniquely satisfies the Government's minimum operational requirements by providing a commercially available, integrated architecture that enables multiple reconnaissance equipment to operate as a single interoperable solution. The Government's minimum need is not satisfied by individual commercial components operating independently, as the operational requirement depends on continuous interoperability among various equipment.

Further, the equipment that is the basis of this Justification is the same as that has been used for the past three (3) years in connection with USMS training with respect to structure operations. Thus, extending this requirement to other than the Axon Sky-Hero would introduce significant operational risk and downtime relating to training on alternative equipment.

Accordingly, this acquisition specifies the Axon Sky- Hero brand name pursuant to FAR Overhaul 6.103-1(d).

The brand-name specification is necessary to ensure compatibility, interoperability, and operational reliability throughout the deployed ground tactical robots and drones USMS utilizes for its missions. Allowing alternate manufacturers would introduce an unacceptable risk that individual components would not operate together as an integrated system, thereby preventing the Government from meeting its minimum operational requirements.

Efforts made to Promote Competition

The Government conducted market research in accordance with FAR Overhaul Part 10 to identify commercially available ground tactical robot solutions capable of satisfying the Government's minimum operational requirements. The market research included a review of commercially available ground tactical robots, available manufacturers, authorized commercial distribution channels, and existing Government acquisition vehicles.

The Government considered whether a performance-based or brand-neutral specification would satisfy its minimum needs. Market research determined that the

FAR Overhaul Part 6 JOFOC for FY26 TD AXON SKY-HERO 15M10426QA470008

Revision dated 10 April 2026

Government's operational requirement for a fully integrated ecosystem could not be reasonably achieved through a brand-neutral specification without introducing unacceptable technical, training, and operational risk.

Method for Determining Fair and Reasonable Pricing

Based on current market research, Axon has only one authorized distributor for the required equipment.

The Contracting Officer will determine price fairness and reasonableness using price analysis techniques applicable to commercial acquisitions. The Government will evaluate proposed pricing against the Independent Government Cost Estimate (IGCE), current commercial market research, comparison of the proposed price with prior purchases by USMS of the same or substantially similar equipment, and other relevant pricing information available at the time of award.

The Contracting Officer will also utilize other appropriate price analysis techniques in accordance with FAR Overhaul Part 12 to determine price fairness and reasonableness.

Results of Market research

Market research was conducted in accordance with FAR Overhaul Part 10 to identify commercially available ground tactical robots capable of satisfying the Government's minimum operational requirements. The research included a review of commercially available ground tactical robot manufacturers, authorized commercial distribution channels, existing Government acquisition vehicles, historical procurement information, and commercially available product information.

No single technology solves every operations challenge across every terrain, mission profile or threat environment and the commercial marketplace does not accept buying these technologies independently. Instead, the trend is to enable the vendors to operate through distribution agreements.

Here, it appears that Axon has only one authorized distributor for the equipment. Notwithstanding, the solicitation will be posted on sam.gov.

The market research did not identify any other commercially available brand-name ecosystem capable of satisfying the Government's minimum operational

FAR Overhaul Part 6 JOFOC for FY26 TD AXON SKY-HERO 15M10426QA470008

Revision dated 10 April 2026 requirements without introducing unacceptable technical and operational risk associated with interoperability, compatibility, and system integration.

Additional Supporting Facts (If Applicable)

N/A.

Interested Sources

At the time of this justification, no prospective offerors have formally expressed interest in this acquisition. A list of interested sources, if any, will be maintained in the official contract file in accordance with FAR Overhaul 6.104-1(a)(10). Additionally, by posting this requirement on sam.gov, other interested sources will have an opportunity to notify the USMS of capabilities.

Actions to Increase Competition:

In accordance with FAR Overhaul 6.103(b)(1), the Government will continue to evaluate opportunities to increase competition in future acquisitions. Prior to each subsequent procurement, the Government will conduct updated market research to determine whether additional manufacturers, commercial technologies, or interoperable ground tactical robots have become available that satisfy the Government's minimum operational and compatibility requirements.

The Government will also monitor advancements in commercially available ground tactical robot technologies, interoperability standards, and authorized commercial distribution channels to determine whether future procurements may be competed using less restrictive specifications.

If future market research demonstrates that multiple commercially available ground tactical robots are capable of meeting the Government's minimum requirements without compromising interoperability, training, or operational performance, the Government will revise the acquisition strategy to maximize competition to the greatest extent practicable.