CLEAR_FSS_Sole_Source_JA_Signed_Redacted.pdf

contract. West’s schedule GS-02F-026DA includes Order-Level Materials (OLM). The Government will identify and administer the OLM in accordance with applicable FSS ordering procedures.

6.2 Efforts to Identify Other Schedule Sources

The RFQ posted on GSA eBuy was for the smaller portion of the overall requirement, directed to 19 vendors under MAS categories 511120 and ANCILLARY. It allowed quotation of the specified CLEAR components and required vendors to identify any content not priced on their Schedule contracts. Only one responsive quotation was received, from West Publishing Corporation; no resellers or other Schedule contractors responded. Subsequent research in GSA eLibrary and GSA Advantage confirmed that no other Schedule source offered CLEAR. This portion of the requirement was later determined to be inseparable from a broader investigative-platform need and was combined into a single acquisition.

6.3 Pricing

The Contracting Officer will address pricing for the authorized OLM in accordance with applicable FSS ordering procedures. Supporting price analysis will be retained in the contract file.

6.4 Proprietary Source Support

GBO, World-Check, and Adverse Media with Sanctions are proprietary Thomson Reuters datasets. West Publishing Corporation is the Thomson Reuters contracting entity furnishing the integrated CLEAR solution and is the direct provider, not a reseller. No other firm was identified as holding the right to license those datasets within the CLEAR environment.

7. Market Research

The FCC conducted market research in early 2026 and refreshed it later in the year. Its analysis found that no single investigative platform met all required capabilities. The FCC then briefly posted an RFQ. West Publishing later submitted a detailed quotation separating core and enhanced configurations and noting which content was on its schedule contract. The FCC subsequently confirmed schedule availability and reviewed current product information for comparable public-records and risk-intelligence platforms.

Prior solicitation. RFQ1800646 was issued before RFO-2026-8 took effect, as brand name only under then-applicable FAR 8.405-6(b)(1); equal, comparable, or substitute products were excluded and would not have been evaluated. It therefore tested Schedule and reseller availability and price for CLEAR, not whether a non-CLEAR product could satisfy a functional requirement, and is not relied upon for that purpose. The solicitation closed without award. The FCC subsequently determined that the expiring -user core subscription and the enhanced configuration should be acquired as a single enterprise subscription managed by LIBR beginning October 1, 2026;

the prior RFQ is not the basis for award of that expanded requirement. The disposition of RFQ1800646 is documented in a memorandum to the acquisition file.

Source verification. GSA eLibrary identifies West Publishing Corporation under GS-02F-026DA, including SINs 511120 and 511210, together with authority for OLM. Thomson Reuters Special Services LLC contract 47QRAA24D009W lists SINs 541715 and 561450, together with authority for OLM, and does not offer CLEAR under the relevant subscription SINs. A GSA Advantage keyword search for CLEAR filtered to SIN 511120 returned no other Schedule contract. Dated screen captures are retained in the acquisition file. Together with the absence of any reseller response to RFQ1800646, the Contracting Officer finds that West Publishing Corporation is the only Schedule source capable of furnishing CLEAR and its integrated proprietary datasets.

Alternatives. LexisNexis Accurint and TransUnion TLOxp are capable for a stand-alone core public-records requirement. Neither delivers global beneficial ownership and daily-updated sanctions, PEP, and state-owned-entity screening resolved against the same public-record entity index; pairing either with a separate risk or diligence product places those results outside the public-record entity resolution and requires the investigator to re-identify the subject at the point of escalation. Dedicated risk-intelligence and ownership platforms are capable within their scope but lack the U.S. public-record depth and the live telephone, motor-vehicle, and credit-header gateway access the core population requires. An assembled multi-vendor solution is technically possible but not operationally equivalent, for the reasons at Section 4. This conclusion is limited to the FCC’s enterprise minimum need and does not state that competing products are generally incapable.

8. Best Value and Price Determination

The Contracting Officer determines that the proposed order represents best value based on satisfaction of the Government’s minimum needs, use of GSA MAS pricing and terms for the Schedule-priced content, and the results of the Government’s price analysis. Supporting price analysis, including the analysis applicable to OLM, will be retained in the contract file.

9. Other Supporting Facts

The proposed order will be placed under West’s FSS contract. The OLM will be separately identified and administered in accordance with applicable FSS ordering procedures.

10. Actions to Remove Barriers to Future Competition

EAC and LIBR with appropriate technical and mission personnel will jointly continue to survey the market. It will evaluate whether competing public-records platforms can meet the core enterprise need; whether beneficial-ownership, sanctions and politically exposed person, and adverse-media capabilities can be acquired competitively and separately without impairing cross-office referral, entity resolution, timeliness, compliance, or total cost;

whether any additional Schedule source or authorized reseller has become available; and the lifecycle cost of one integrated platform against multiple tools. Results will be placed in the contract file and used to decide whether the next acquisition remains sole source, uses brand-name-or-equal functional specifications, or separates the public-records and risk-intelligence requirements.

11. Certifications

Each certifying official certifies only data under that official’s cognizance. These certifications cover the entire FSS order, including the OLM.

Requiring Activity — I certify that the facts and representations under my cognizance included in this justification are complete and accurate.

Contracting Officer Certification and Approval - I certify that this justification is accurate and complete to the best of my knowledge and belief. Based on the supporting facts and market research, I approve placement of the order on a sole-source basis under GSA FSS Ordering Procedures 538.7104-3(b)(1)(ii).

12. Publication

No synopsis under RFO FAR Part 5 is required because the acquisition is placed under the GSA FSS Ordering Procedures. Because the order is supported by an executed and approved sole-source justification under 538.7104-3(b), no eBuy posting is required. The Contracting Officer may issue the RFQ directly to West Publishing Corporation.

The approved justification will be made publicly available at the Government-wide point of entry within 14 days after award and kept available for at least 30 days, consistent with 538.7104-3(b)(3). Before posting, it will be screened to remove contractor proprietary data, including line-item pricing and the FSS-priced and non-schedule-content breakout, and to identify information exempt from disclosure under the Freedom of Information Act or prohibited from disclosure under RFO FAR Part 24.