I_4_ JOFOC_REV Version2 1 signed.pdf

IRS Form (Rev. 6/21)

IRSAP 1006.3

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

(JOFOC)

FAR SUBPART 6.3

I recommend the use of other than full and open competition for the acquisition of the following supplies or services. If this acquisition is to be made with only one source or a limited number of sources, negotiations will be conducted with the indicated proposed supplier(s).

1. IDENTIFICATION OF THE AGENCY AND CONTRACTING ACTIVITY:

IRS - Criminal Investigation (CI) Tier 1 Previous contract #2032H5-23-F-00839/Requisition #5000169451

2. NATURE/DESCRIPTION OF THE ACTION BEING APPROVED:

The purpose of this Brand Name Justification is to obtain a Firm Fixed Price (FFP) Brand Name contract for the purchase of the i2 Software Subscription five (5) year contract including one 12-month base and four 12-month option years

Contract Type: Firm Fixed Price Contract number of the proposed contractor:

TBD

Period of Performance:

BY 03/15/2025 – 03/14/2026

OY I 03/15/2026 – 03/14/2027

OY II 03/15/2027 – 03/14/2028

OYIII 03/15/2028 – 03/14/2029

OY IV 03/15/2029 – 03/14/2030

3. DESCRIPTION OF SUPPLIES OR SERVICES:

A description of the supplies or services required to meet the agency’s needs:

IRS-CI has the following critical requirements:

• Software that can create, organize, and present investigative data in link analysis charts while also presenting relational data links.

• Software that can read, modify and display existing complex .anb, .anx, and .ant files. Access to these existing proprietary file types are critical to IRS-CI in current investigations and prosecutions. Additionally, IRS-CI also needs access to these existing proprietary file types for adjudicated cases in the event of remand from appeal. These file types are also used by law enforcement partners and by the United States Attorney’s Office for investigative link analysis visualizations. It is critical to be able to share these files between agencies in join investigations and federal prosecutions.

The proposed acquisition is to acquire the following i2 sole-source products:

i2 enables law enforcement professionals to create evidence-driven knowledge graph data visualizations. This allows for the visual representation of relationships between suspects and other people of organization in their criminal networks. It also enables the visualization of financial tracing in criminal investigations and prosecutions. By using i2 technology, investigators can build comprehensive case files and uncover critical information that may otherwise remain hidden.

The .anb, .anx. and .ant files types are proprietary to i2. No other software is known that can effectively utilize these file types. i2 is the standard link analysis software used among federal law enforcement.

130 qty - i2 Analyst's Notebook Concurrent User Annual Subscription & Support

Base Year Total: $ 400,010.00 Optional Year 1 Total: $440,011.00 Optional Year 2 Total: $484,012.10 Optional Year 3 Total: $532,413.31 Optional Year 4 Total: $585,654.64

4. SHOPPING CART

NUMBER:

5000199561

5. NAME OF PROPOSED SOURCE(S):

TBD

6. COST ESTIMATE:

$2,442,101.05

7. CERTIFICATION OF TECHNICAL OR REQUIREMENTS PERSONNEL

I hereby certify that any supporting information and data provided, which form the basis for this justification, are accurate and complete to the best of my knowledge and belief.

PROGRAM OFFICE (Requiring Activity) (Name & Title)

Allen Pride, Supervisory Special Agent

(Signature)

Allen F. Digitally signed by Allen F. Pride

Pride Date: 2025.03.27 14:50:07 -05'00'

(Phone No.) (Date)

8. PROCUREMENT OFFICE CERTIFICATION

This requirement [ ] will / [ ] will not provide for a bridge contract.

I certify that this submission is accurate and complete to the best of my knowledge and belief. This certification will serve as approval, unless action exceeds $750K.

CONTRACTING OFFICER

(Name)

Alison Adamson

(Signature)

Alison M. Digitally signed by Alison

M. Adamson

Adamson Date: 2025.03.27 13:15:14 -06'00'

(Phone No.)

(801) 620-3437

(Date)

3/27/2025

Before requesting this procurement, state one statutory authority for this procurement to be conducted under “other than full and open competition” procedures. Provide narrative justification associated with the respective state authority in block number 10.

9. THE COMPETITION IN CONTRACTING ACT OF 1984 (P.L. 98-369)

(place “X” in appropriate box)

X

41 U.S.C. § 3304(a)(1), FAR 6.302-1– Only one responsible source; or brand name specification

41 U.S.C. § 3304(a)(2), FAR 6.302-2 – Unusual and compelling urgency

41 U.S.C. § 3304(a)(3), FAR 6.302-3 – Industrial mobilization, engineering, developmental, or research capability; or expert services

41 U.S.C. § 3304(a)(4), FAR 6.302-4 – International agreement

41 U.S.C. § 3304(a)(5), FAR 6.302-5 – Authorized or required by statute

41 U.S.C. § 3304(a)(6), FAR 6.302-6 – National Security

41 U.S.C. § 3304(a)(7), FAR 6.302-7 – Public Interest

10. JUSTIFICATION

(add pages if needed)

A. DEMONSTRATION THAT THE PROPOSED CONTRACTOR’S UNIQUE QUALIFICATIONS OR

THE NATURE OF THE ACQUISITION REQUIRES USE OF THE AUTHORITY CITED.

IRS-CI has the following critical requirements:

• Software that can create, organize, and present investigative data in link analysis charts focusing on relational data links.

• Software that can read, modify and display existing complex .anb, .anx, and .ant files (hereafter proprietary file types). Access to these existing proprietary file types are critical to IRS-CI in current investigations and prosecutions. Additionally, IRS-CI also needs access to these existing proprietary file types for adjudicated cases in the event of remand from appeal. These proprietary file types are also used by law enforcement partners and by the United States Attorney’s Office for investigative link analysis visualizations. It is critical to be able to share these files between agencies and prosecutors in joint investigations and federal prosecutions.

IRS utilized I2 Analyst Notebook to build complex relational investigative data visualizations that enable investigators to document financial flows, criminal organizational charts, and to document how disparate evidence comes together to prove criminal violations. Numerous IRS Special Agents built complex data visualizations on multiyear investigations using the proprietary file types that are stored and accessed via i2 Analyst Notebook. I2 Analyst Notebook is the only software that can access these proprietary file types. The success of numerous IRS criminal investigations and prosecutions are dependent on being able to access the investigative casework summarized in the proprietary file types. This investigative casework cannot be recreated without substantially harming the investigations and associated prosecutions.

FAR 6.302-1(a)(2), FAR 6.302-1(b)(1)(i) and 41 U.S.C. § 3304(a)(1) apply in this matter as Harris Computer i2 Analyst Notebook Group (ANG) is the only vendor that directly offers i2 software to the government. ANG is the only responsible source and no other software will satisfy the needs of IRS- Ci due to the fact that i2 Analyst Notebook is the only software that can utilize .anb, .anx, and .ant files (hereafter “proprietary file types”).

A multi-vendor approach for software other than i2 Analyst Notebook is not feasible as no other software exists that can modify the proprietary file types. Market research shows no other vendor offers products that can effectively access ANG’s proprietary file types. A multi-vendor approach for i2 Analyst Notebook was performed with RFI’s issued via NASA SEWP and Army Chess

Resellers identified in market research that offer i2 Analyst Notebook are: Advanced Computer Concepts, Enterprise Technology Solutions, New Tech Solutions, Bahfed, Metgreen Solutions, OCG Telecom, Software Information Resource Corporation, Cirrus Systems/FSR Consulting, Kambrian, and SHI.

Simply stated, i2 Analyst Notebook is uniquely qualified and the only product capable of meeting IRS requirements.

Without I2 Analyst Notebook, CI will have reduced capacity to analyze new investigative data and will not be able to access critical investigative data visualizations critical to ongoing investigations and prosecutions. In addition, CI will have reduced capacity collaborating with other Federal Law Enforcement that use i2 and the ANG proprietary file types.

B. DESCRIBE THE EFFORTS TAKEN TO ENSURE OFFERS WERE SOLICITED FROM AS MANY

POTENTIAL SOURCES AS IS PRACTICABLE, INCLUDING WHETHER A NOTICE WAS OR

WILL BE PUBLISHED AS REQUIRED BY FAR SUBPART 5.2 AND, IF NOT, WHICH

EXCEPTION UNDER FAR 5.202 APPLIES.

Two RFI’s were posted to NASA SEWP and GSA for Software that can create, organize, and present investigative data in link analysis charts while also presenting relational data links that can read, modify, and display .anb .anx .ant files. Those RFIs returned New Tech Solutions as the only vendor capable of fulfilling that need. New Tech Solutions is an authorized reseller of i2 Analyst Software currently in use by the Government

Because i2 Analyst Notebook is the only product that can access the proprietary file types, offers were solicited from vendors that offer i2 Analyst Notebook. These vendors are ANG and resellers previously discussed in the page above.

The contract specialist, Rickey Lawrence solicited the following sources for potential vendors.

An RFI was placed on Army Chess that returned two authorized resellers one a small business the other a large business preventing adequate competition

An RFI was also placed on NASA SEWP that returned 2 authorized resellers as well as and additional vendor who stated they would be able to provide the software services. However, these were not value adding resellers.

As a result of the responses received a solicitation will be placed on SAM.gov

C. DETERMINATION THAT THE ANTICIPATED COST TO THE GOVERNMENT WILL BE FAIR

AND REASONABLE.

The Contracting Officer will determine that the anticipated prices will be fair and reasonable based on a comparison of the proposed prices received in response to the solicitation and comparison of the proposed prices with the Independent Government Cost Estimate (IGCE).

D. DESCRIBE THE MARKET RESEARCH THAT WAS CONDUCTED AND THE RESULTS OF

THAT SURVEY. IF ACTIONS WERE TAKEN BY PROCUREMENT PERSONNEL TO SATISFY

THIS REQUIREMENT (SUCH AS A GPE SOURCES SOUGHT SYNOPSIS), PLEASE SPECIFY.

Treasury Mandatory Sources must be considered in accordance with DTAP part 1008 as well as small businesses in accordance with DTAP part 1010 and 1019. See SF 1010 Market Research Summary Report.

Market research was conducted by the Contracting Officer and Program Office between November 2024 and January 2025. The results of the market research supported the Government’s determination to obtain these services under a brand name basis. Refer to the SF 1010 Market Research Summary Report for specific details.

E. DESCRIBE ANY OTHER FACTS TO SUPPORT THE JOFOC.

These service and support were previously acquired:

Previous contract 2032H5-23-F-00839/Requisition #5000169451 IRS-CI currently has use i2 Analyst Notebook for over a decade. It is widely deployed across federal law enforcement. I2 was previously owned by IBM. In previous years i2 was acquired from the IBM ELA Contract GS-35F-0312U.

In 2022, i2 was sold from IBM to Harris Computing. As i2 is not owned by IBM a separate contract must be established.

F. LIST SOURCES, IF ANY, THAT EXPRESSED, IN WRITING, AN INTEREST IN THE

ACQUISITION.

New Tech Solutions – Small Business BahFed – HUBZone VOSB EnterpriseTechnology Solutions Inc -Large

SIRC- WOSB

G. LIST THE ACTIONS THE BUREAU WILL TAKE TO REMOVE OR OVERCOME ANY BARRIERS

TO PROMOTE THE COMPETITION ON ANY SUBSEQUENT ACQUISITIONS FOR SIMILAR

SUPPLIES OR SERVICES.

To ensure fair opportunity is achieved; the IRS will continue to remove or overcome any barriers by investigate the marketplace for the best investigative data visualization solutions that for the IRS. We will investigate the best options and if appropriate implement a phased transition to another software with non-proprietary file types.

H. STATEMENT THAT REQUIREMENT DOES NOT RESULT FROM A LACK OF PLANNING OR

THE EXPIRATION OF FUNDS.

This requirement does not result from a lack of planning or expiration of funds. This request is for the recompete of existing expired contract.

11. ADDITIONAL APPROVALS

O

VE

R$

M

IL

LI

O N

M

IL

LI

O

N

A. BUREAU CHIEF

INFORMATION OFFICER

(for IT only) (Name & Title)

(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).)

[ ] APPROVE

[ ] DISAPPROVE

N/A

(Date)

O

VE

R $7

,0

B. BUREAU COMPETITION

ADVOCATE (Name & Title)

Julius S. Bradshaw

[X ] APPROVE

[ ] DISAPPROVE

(Signature) (Phone No.)

240.613.7395

(Date)

3/27/2025

O

VE

R $1

M

IL

LI

O N

C. HEAD OF THE

PROCURING ACTIVITY OR

AUTHORIZED DESIGNEE

(Name & Title)

[ ] APPROVE

(Date)

O

VE

R $7

M

IL

LI

O N

D. TREASURY CHIEF

INFORMATION OFFICER

(for IT only) (Name & Title)

[ ] APPROVE

(Date)

O

VE

R $7

M

IL

LI

O N

E. SENIOR

PROCUREMENT

EXECUTIVE (Name & Title)

[ ] APPROVE

[ ] DISAPPROVE

(Signature) (Phone No.)

(Date)

NOTE: Each review must be preceded by lower level approval(s). For example, actions over $75 million require all approvals.

IN NO CASE WILL AN INDIVIDUAL SIGN MORE THAN ONE APPROVAL LEVEL.