JOFOC No.: ATF-26-0004

Version MAR 2025 commercial database of reporting records from businesses that deal in the secondary market of goods, to include crime guns.

3. A description of the supplies and/or services required, including the delivery schedule and/or the period of performance (inclusive of all option periods), and the estimated dollar value of the acquisition.

This action is for the purchase of the commercial software solution or suite of services from LeadsOnline solution with uninterrupted 24/7 access to support the Operational Intelligence Division with a web platform that supports unlimited ATF users with access to secondary market pawnshop and dealer transaction records. The purpose of this requirement is to enable ATF personnel to identify and locate crime guns, other secondary market items, or individuals associated with ATF criminal investigations once those items or individuals appear in the secondary market records system. The system must allow authorized users to submit firearm identifiers (make, model, serial number) or relevant item information, perform investigative queries to identify recent transactions, link sales to specific merchants or locations, and support ongoing investigations. The requirement includes both ad hoc and bulk querying, with projected usage scaling to accommodate current and future investigative workloads. Sustainment requirements include ongoing software support, system updates to maintain combability with participating in merchant data sources, secure data hosting, and adherence to federal security and privacy standards over the lifecycle of the acquisition.

The anticipated period of performance is one base year 2/15/2026 – 2/14/2027 with four (4) 12-month option periods, if exercised.

Base Year 2/15/2026 2/14/2027

(OY 1) 2/15/2027- 2/14/2028

(OY 2) 2/15/2028- 2/14/2029

(OY 3) 2/15/2029- 2/14/2030

(OY 4) 2/15/2030- 2/14/2031

4. Identify statutory authority permitting limiting sources.

This acquisition is conducted under the authority of 41 U.S. Code § 3304 – Use of Non-Competitive Procedures and the exceptions listed under FAR 6.103-1 – Circumstances permitting other than full and open competition.. (Check the appropriate box for the authority – and bold the statement)

☒ FAR 6.103-1 Only one responsible source and no other supplies or services will satisfy agency requirements.

☐ FAR 6.302-2 Unusual and compelling urgency.

☐ FAR 6.302-3 Industrial mobilization; engineering, developmental, or research capability; or expert services.

☐ FAR 6.302-4 International agreement.

☐ FAR 6.302-5 Authorized or required by statute.

☐ FAR 6.302-6 – National Security ☐ FAR 6.302-7 Public Interest

5. A statement demonstrating the unique qualifications of the proposed contractor or the nature of the action requiring use of the authority.

LeadsOnline is uniquely qualified to provide these supplies/goods or services to ATF based upon the following:

A) LeadsOnline is the only secondary market database company that has records from all 50 states and the District of Columbia. LeadsOnline currently serves over 5,000 law enforcement agencies across the country, and more than 100,000 investigators access the LeadsOnline platform each year to advance their cases. LeadsOnline receives transaction information from over 20,000 + businesses across all 50 states. These businesses include secondhand stores, pawn shops, scrap yards, and online marketplaces. National chains such as FirstCash, EZ Corp, GameStop, BestBuy, ecoATM, as well as local businesses across the country recognize LeadsOnline as the easiest way to comply with local reporting ordinances.

B) LeadsOnline is one complete system, managed end-to-end. LeadsOnline owns and manages its entire network. ATF would have enterprise-based access to the network through an unlimited number of licenses. LeadsOnline collects data directly from pawnshops and secondhand stores, most of which do not report in any other way. LeadsOnline manages its own server performance, optimizes database indexing, updates its own code to support browsers, and increases its bandwidth to maintain a rapid system response for its users.

C) LeadsOnline transaction information contains personally identifiable information (PII) of individuals selling items to reporting businesses. This PII does not include any information related to individuals who have purchased a firearm, and ATF will not receive any PII from batch firearm traces.

D) Stolen item upload: Capability to upload bulk lists of serialized items to be checked against the millions of transactions in Leads Online.

ATF’s goal in accessing an electronic database of secondary market transactions is to shorten the starting point for the tracing of crime guns and thus improve tracing accuracy of crime guns recovered in crimes, and more expediently, determine the most recent purchaser of crime guns recovered through criminal investigations. As a federal law enforcement agency, ATF requires the largest geographic area of coverage and access to the most current regulated industry transaction information possible

Alternative to #5 for brand name products. A demonstration of any brand name product’s unique attributes: An explanation of the unique attributes of the proposed brand name item(s) and why no other similar item will suffice.

LeadsOnline are uniquely qualified to meet the agency’s needs based on the following:

a. LeadsOnline’s data solution provides unique, nationwide, comprehensive data for law enforcement. ATF can Instantly search across 2+ billion transaction records, collected lawfully from pawn, secondhand, and scrap yards (incl. 1+ billion images and more than 80 million unique persons) from over 20,000 reporting businesses in all 50 states. LeadsOnline integrates with more than 100 different Point of Sale (POS) systems and more than 1,000 different formats that reporting businesses use to run their business. With LeadsOnline, ATF users can easily query for suspects and property. Search capabilities include suspect name, ID, address, and phone number, in addition to description, make, model, and serial number for crime guns. Results are delivered within seconds and users can drill down into the history of specific transactions.

b. LeadsOnline also has an API to eBay and OfferUp to help investigators work on cases that may involve those platforms from the LeadsOnline investigations system.

c. LeadsOnline transaction information contains personally identifiable information (PII) of individuals selling items to reporting businesses. This PII does not include any information related to individuals who have purchased a firearm, and ATF will not receive any PII from batch firearm traces.

d. NCIC Stolen Property Notifications: All serialized transactions are run against the NCIC stolen property database, and ATF can receive automated alerts on property including crime guns, articles and vehicles from ATF cases found within and outside of jurisdiction.

Furthermore, LeadsOnline uses the proprietary DS algorithm to prioritize matches based on the probability it is a match worth investigating.

Based on the RFI responses, Duality Technologies and Peregrine Technologies, are both not qualified to meet ATFs requirement for this acquisition. Duality Technologies and Peregrine Technologies stated that they do not provide or maintain secondary market data directly; rather their platform functions as a gateway that enables users to query third party data aggregators. ATF would need to enter into agreements with data providers and access their data via Duality. This approach does not satisfy the Governments requirement for direct access to authoritative, system of record secondary market data.

A Source Sought was posted to SAM.GOV from 12/9/2025- 12/17/2025 requesting that parties express in writing their interest to the contracting officer. Two contractors responded prior to the deadline; Duality Technologies and LeadsOnline. A third response was made past the deadline by Peregrine Technologies. Although the response was received after the stated RFI response deadline, the Government reviewed and considered the submission as part of its market research efforts to ensure due diligence and a comprehensive understanding of available industry capabilities. Responses were evaluated against ATFs minimum requirements for access to secondary market transaction data. The evaluation focused on the vendor’s ability to provide direct access to comprehensive secondary market coverage, crime gun serial number searches capability, investigative query tools, system integration, and sustainment support.

Both Duality Technologies and Peregrine Technologies responded to the RFI initially indicating that they could meet the Governments stated requirements; however, during subsequent written clarification and follow up exchanges, it was confirmed both vendors’ solution does not provide the secondary market pawn or dealer transaction records/data, ecoATM or scrap metal reporting, or other regulated merchant data directly. While their platform enables users to query third party data aggregators, this approach does not deliver the core functional requirements needed to support ATF criminal investigations. Market research determined Duality Technologies and Peregrine Technologies function as gateways or analytic layer enabling users to query data maintained by third party secondary market data providers. Duality Technologies and Peregrine Technologies both do not maintain and provide direct access to the data required. As a result, use of these platforms would require the Government to enter into separate subscriptions or contractual agreements with multiple third-party vendors to obtain the necessary data. This approach does not meet the Governments’ requirement for comprehensive direct access to secondary market system of record data under a single contractual vehicle and introduces additional acquisition complexity, operational dependency, sustainment risk, and increased lifecycle costs. Accordingly, these gateway solutions do not satisfy the Governments’ minimum, operational and cost-effective requirement. In contrast, market research determined that LeadsOnline meets the Governments’ requirements by providing direct, comprehensive access to secondary market system of record data under a single contractual vehicle. LeadsOnline provides a mature, purpose-built solution offering direct access to nationwide pawns, secondhand dealers, ecoATM, and scrap metal transaction records, serial number crime gun searches, investigative query tools, audit logging, API access, and established participation by regulated merchants. This allows authorized users to perform real time and historical searches. This platform supports investigative workflows that enable identification and location of crime guns, secondary market items, and associated individuals once they appear in secondary market records, without reliance on third party data subscriptions or additional contracts. Based on these findings, Duality Technologies and Peregrine Technologies cannot meet ATFs minimum operational requirements, while LeadsOnline is currently the only vendor capable of supporting ATFs secondary market program and investigation mission making LeadsOnline the only source capable of fulfilling ATFs current and projected needs for this requirement.

11. A statement of any actions the agency will take to remove or overcome any future barriers to competition.

To remove or mitigate potential future barriers to competition, the Government will continue to conduct periodic market research assessing emerging technologies and data sources that may expand the availability of nationwide secondary market system of record data capable of meetings ATFs operational requirements.

12. Certifications.

Co-Prepared by:

As the Contracting Officer’s Representative (COR) or Government’s Technical Representative (GTR), I certify the above information is accurate to the best of my knowledge and contains complete data/information necessary to support the recommendation and the basis for this justification.

, COR/GTR Date

OPERATIONAL INTELLIGENCE DIVISION

As the Contracts Specialist, I reviewed the information presented above by the program office, this information is complete and accurate to the best of my knowledge. I recommend to the Contracting Officer it is in the best interest of the US Government to pursue other than full and open competition for this requirement.

, Contracts Specialist Date Office of Management – Acquisitions Management Division

As the Contracting Officer and based on the information presented by the program office, the information is complete and accurate to the best of my knowledge, and it is in the best interest of the US Government to pursue other than full and open competition for this requirement.

Amanda Boshears, Contracting Officer Date Office of Management - Acquisitions Management Division

Reviewed by:

, Branch Chief4 Date

Approved by:

, Contracting Officer5 Date Office of Management - Acquisitions

I have reviewed this justification and find it to be accurate and complete to the best of my knowledge and belief. Recommend approval at all levels exceeding $750K.

Date Bureau Procurement Chief

As the ATF Competition Advocate, I have reviewed this justification and find it to be accurate and complete to the best of my knowledge and belief. Since this LSJ does not exceed $75M, this review serves as approval.

Date Bureau’s Competition Advocate Assistant Director (AD)– Office of Management

4 For all actions over $750K, Branch Chief review is required.

5 CO is the final approval for all actions $750K and below.

6 For all actions over $750K, BPC review is required.

7 CA is the final approval for all actions above $750K but not exceeding the $75M threshold.