M4_Trainer Weapons Sole Source Justification- Signed.pdf

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535TRS M4 TRAINER WEAPONS
Solicitation number
FA301626Q0281
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This is a Sole Source Justification document for a federal procurement of M4 Trainer Weapons. The 535th Training Squadron at JBSA Lackland requires 350 M4 Trainer Weapons—specialized, non-live-fire simulator training devices that replicate the exact physical characteristics, weight, and mechanical function of standard-issue military M4 rifles. These trainers will enable recruits to master weapon handling, safety procedures, and disassembly/reassembly mechanics in a controlled environment while eliminating live-fire safety hazards and reducing arms-room weapon tracking requirements.

The sole source contractor is Laser Shot, Inc., located at 4214 Bluebonnet Drive, Stafford, Texas 77477-2911 (CAGE Code 3BFG4; UEI G62XKQN4AQ4). The justification asserts that only Laser Shot's proprietary design meets the 535th Training Squadron's minimum essential needs, including 10-part field-strip disassembly mechanics, permanent safety features that prevent conversion to live-fire weapons, and verified ATF-exempt training status. Laser Shot holds exclusive proprietary manufacturing and design rights acquired from Olympic Arms, Inc., and market research—comprising GSA Advantage queries, Small Business Searches, and a targeted Request for Information—confirmed no alternative products satisfy the required safety and instructional standards. The procurement will be executed as a direct Request for Quote using an SF 1449, supported by a pre-published Notice of Intent to Sole Source on SAM.gov. Pricing will be verified as fair and reasonable per DFARS 212.204(a) prior to award. The Contracting Officer Ramon Marrufo, GS-13, DAF, signed the determination on September 4, 2026.

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SOLE SOURCE JUSTIFICATION

M4 TRAINER WEAPONS

1. CONTRACTOR'S NAME & ADDRESS:

Name: Laser Shot, Inc.

Address: 4214 Bluebonnet Dr, Stafford, TX 77477-2911 CAGE Code: 3BFG4

UEI: G62XKQN4AQ4

2. ESTIMATED DOLLAR VALUE OF PROPOSED REQUIREMENT:

Estimated Value:

3. JUSTIFICATION:

a. Brief non-technical description of the supplies/services to be acquired:

The 535th Training Squadron at JBSA Lackland requires three hundred and fifty (350) M4 Trainer Weapons. These specialized, non-live-fire simulator training devices replicate the exact physical characteristics, weight, and mechanical function of a standard-issue military M4 rifle. Recruits will use these trainers to master weapon handling, safety procedures, and disassembly/reassembly mechanics in a controlled environment, eliminating live-fire safety hazards and reducing restrictive arms-room weapon tracking.

In accordance with Revolutionary Federal Acquisition Regulation Overhaul (RFO) 6.104-1, the Contracting Officer shall execute a written justification to support a sole source direction for acquisition valued over the Simplified Acquisition Threshold (SAT).

The regulatory authority permitting this non-competitive procurement is RFO 6.103-1, Only one responsible source and no other supplies or services will satisfy agency requirements, specifically under the statutory authority of 10 U.S.C. 3204(a)(1) or 41 U.S.C. 3304(a)(1). Per RFO 6.103-1(d), the specification of attributes peculiar to one manufacturer restricts full and open competition and is justified herein because only Laser Shot's proprietary design meets the 535th Training Squadron minimum essential needs, requiring approval under RFO 6.104. This document serves as the mandatory justification to authorize direct solicitation from Laser Shot, Inc.

b. Clear concise statement of the facts justifying the sole source contract:

The Laser Shot M4 Trainer Weapons are the only training devices that satisfy the minimum essential training requirements of the 535th Training Squadron. This specific brand is uniquely required to maintain absolute instructional continuity and direct compatibility with JBSA Lackland's existing training inventory, technical manuals, and established Basic Military Training (BMT) curriculum. Introducing any alternative brand would generate critical training inconsistencies among trainees, invalidate active instructional media, and require a highly disruptive, costly overhaul of established lesson plans.

c. Unique capabilities possessed by only one contractor:

Laser Shot, Inc. holds the exclusive proprietary manufacturing and design rights for this M4 Trainer Weapon, having legally acquired them from Olympic Arms, Inc. No other contractor or manufacturer can legally produce or supply this design.

These proprietary capabilities are essential for contract performance due to the following safety and functional design features:

1. Mechanical Realism: Replicates the exact weight, physical form factor, and standard 10-part field-strip disassembly mechanics of an actual military-issue M4 duty weapon.

2. Safety & Non-Convertibility: Utilizes permanent, destructive material-removal paths in the manufacturing process to render the receiver physically incapable of being converted to a live-fire weapon.

3. Regulatory Compliance: Includes verified internal design safeguards that guarantee a certified, unrestricted, and arms-room-free ATF-exempt training status.

d. Only known source statement:

Market research—consisting of GSA Advantage queries, a Small Business Search (SBS), and a targeted Request for Information (RFI)—confirms that Laser Shot, Inc. is the only known source capable of satisfying the Government's requirement. Alternative products analyzed during market research failed to meet the 535th Training Squadron safety and instructional standards because they either lacked the required 10-part field-strip mechanics, lacked the mandatory ATF exemption, or were designed to fire dummy/mock ammunition instead of operating as inert mechanical replicas.

Because Laser Shot, Inc. does not utilize authorized resellers or distributors and retains all proprietary rights, they alone can provide the required safe, compliant, and interoperable training weapons.

e. Actions to be taken by the requiring activity to preclude the necessity for future sole source acquisitions:

To preclude the necessity of future sole-source acquisitions, the requiring activity will continuously monitor the marketplace for emerging simulator technologies and new weapons training aids. The Government will perform routine market surveys, attend industry training expositions, and review future Small Business Search (SBS) and SAM.gov vendor catalogs ahead of subsequent requirements. If alternative, compliant, and interoperable training weapon systems are developed by other manufacturers in the future, they will be actively considered for competitive procurements.

4. MANUFACTURER APPLICABILITY & STRATEGY:

This requirement is a sole-source procurement because only Laser Shot's proprietary product design meets the 10-part field-strip mechanical fidelity and certified ATF arms-room exemption required for JBSA Lackland's non-live-fire recruit training curriculum. Under the Revolutionary FAR Overhaul (RFO) Part 12 Simplified Procedures (RFO 12.201-1), this action will be executed as a direct Request for Quote (RFQ) using an SF 1449 issued directly to the manufacturer, supported by a pre-published Notice of Intent to Sole Source on SAM.gov that has fully run its course.

5. DETERMINATION & APPROVAL

Based on the market research and facts presented above, the Contracting Officer determine that only one source is reasonably available to satisfy this requirement. The pricing will be verified as fair and reasonable in accordance with DFARS 212.204(a) prior to award.

RAMON MARRUFO, GS-13, DAF

Contracting Officer

2026-09-04T17:47:38-0500
MARRUFO.RAMON.1513248489

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