OTFO JA FCI Redacted.pdf

Full Content Inspection (FCI)

CUI

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Controlled By: DISA Controlled By: BDL/BDL2 CUI Category: PROCURE Distribution/Dissemination Control: FEDCON POC: Elmer Gordon, elmer.a.gordon.civ@mail.mil, (240) 484-6695

JUSTIFICATION FOR OTHER THAN FULL AND

OPEN COMPETITION (OTFAOC)

Federal Acquisition Regulation (FAR) Part 6 Justification & Approval (J&A), Supporting Procurements under FAR Part 12, and FAR Part 15

Purchase Request Number: Not Applicable Contract Number: To Be Determined Procurement Title: Full Content Inspection (FCI) Managed Service Estimated Value:

Statutory and Regulatory Authority: 10 U.S.C. 3204(a)(1) and FAR 6.302-1

Justification for OTFAOC Number: JA25-098

Upon the basis of the following justification, I, as Senior Procurement Executive, hereby approve the use of other than full and open competition of the proposed contractual action pursuant to the authority of FAR 6.302-1/Defense FAR Supplement 206.302-1, only one responsible source and no other supplies or services will satisfy Agency requirements.

1. REQUIRING AGENCY AND CONTRACTING ACTIVITY:

Requiring Agency:

Defense Information Systems Agency (DISA) 6910 Cooper Avenue Fort Meade, Maryland 20755

Contracting Activity:

DISA/Defense Information Technology Contracting Organization (DITCO); PS8411 2300 East Drive Scott AFB, Illinois 62225

2. NATURE/DESCRIPTION OF ACTION(S):

a. This action seeks to procure an FCI managed service, utilizing the proprietary Trinity Cyber (TC):Edge commercial off-the-shelf software subscription. The FCI solution will provide TC:Edge capabilities, enabling the detection of malicious cyber activity, automated and real-time threat mitigation, and comprehensive threat analytics for cyber protection teams. DISA requires this capability to deliver secure infrastructure and services across its ecosystem, ensuring DISA and Department of Defense (DoD) mission partners have secure access to their applications. As an enterprise service provider to the DoD, DISA is authorized to provide these critical security services. The FCI solution’s capabilities include deployment, integration, operation, and sustainment, all delivered via TC:Edge as a managed service. This approach will enable

JA25-098-Full Content Inspection (FCI)

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Wide Acquisition Contracts (GWAC), and publishing a Request for Information (RFI) on SAM.gov.

b. First, market research was conducted to determine if another brand-name solution could meet DISA’s requirements. An RFI announcement was publicly posted in October 2024. The RFI requested information on an alternative solution to the current FCI capability and sources who can provide the solution. A total of 31 industry responses were received and based on the government’s assessment, only the current TC:Edge solution meets the agency’s needs. Based on this market research, no other vendor supports an advanced “modify content” cyber threat mitigation option featuring content disarm and reconstruct technologies.

c. The second step in conducting market research was to determine a method of procurement.

DISA Contract Vehicles (ENCORE III, SETI, and DPSS), GWACs included the Information Technology Enterprise Solutions (ITES)-3 Services, ITES-Software 2, National Aeronautics and Space Administration Solutions for Enterprise-Wide Procurement V government-wide acquisition, Multiple Award General Services Administration Schedules and DoD Enterprise Software Initiative agreements and contracts. No DISA-wide contract, DoD or GSA contract was found to meet all the FCI requirements of the managed service and research showed that By Light was the only authorized reseller of TC:Edge.

d. Based on market research, it has been determined that only the aforementioned TC:Edge can fully meet the government’s need for FCI. This requirement is for proprietary products and/or product support and no competitor’s functional replacement products exist in the market currently to meet the government's requirements. The government will continue to conduct market research to determine if there are changes in the marketplace and the government’s requirements that would enable future competitive actions, i.e., there are similar products and/or product support in the marketplace that provides the same functionality, the original equipment manufacturer releases ownership rights of the product, or it is economically feasible to procure a new system.

9. ANY OTHER SUPPORTING FACTS:

None

10. LISTING OF INTERESTED SOURCES:

By Light Professional IT Services, LLC (Large Business - Cage Code 3G4R0) 8484 Westpark Drive, Suite 600 McLean, VA 22102

11. ACTIONS THE AGENCY MAY TAKE TO REMOVE OR OVERCOME BARRIERS

THAT LED TO THE EXCEPTION TO FULL AND OPEN COMPETITION:

a. Procurement History.

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TECHNICAL CERTIFICATION: I certify that the supporting data under my cognizance, which are included in the J&A, are accurate and complete, to the best of my knowledge and belief.

NAME: ELMER GORDON SIGNATURE/DATE:

TITLE/ORGANIZATION: PM/PCOR/ID5

PHONE: 667-890-5228 / elmer.a.gordon.civ@mail.mil

REQUIREMENTS CERTIFICATION: I certify that the supporting data under my cognizance, which are included in the J&A, are accurate and complete, to the best of my knowledge and belief.

NAME: DUNCAN CARTER SIGNATURE/DATE:

TITLE/ORGANIZATION: Division Chief ID5 (Perimeter Defense Division)

PHONE: 667-890-4937 / duncan.a.carter.civ@mail.mil

CONTRACTING OFFICER CERTIFICATION: I certify that this justification is accurate and complete, to the best of my knowledge and belief

NAME: CARRIE M. ROSS SIGNATURE/DATE:

TITLE/ORGANIZATION: DISA/DITCO/PS841

PHONE: (667) 890-2497 / carrie.m.ross.civ@mail.mil

SENIOR PROCUREMENT EXECUTIVE (SPE) APPROVAL: I have reviewed this justification and find it to be accurate and complete, to the best of my knowledge and belief.

Since this justification exceeds $100M, this review serves as approval.

NAME: DOUGLAS W. PACKARD SIGNATURE/DATE:

TITLE/ORGANIZATION: Senior Procurement Executive

PHONE: 301-225-4123

ALL QUESTIONS REGARDING THIS JUSTIFICATION ARE TO BE REFERRED TO Carrie Ross, (667) 890-2497, carrie.m.ross.civ@mail.mil