PAN 025622 Ace MFR JA_Redacted.pdf

For All Actions At or Below the Simplified Acquisition Threshold FAR Subpart 13.1

CUI//SP-PROCURE//FEDCON

Control No: MICC-WP-2025-84<SAT

CUI//SP-PROCURE//FEDCON

Apr 2021

Memorandum for Record – Limiting Competition at or below the Simplified Acquisition Threshold

1. Contracting Activity: Mission Installation Contracting Command- West Point (MICC- WP) 681 Roger’s Place West Point NY 10996.

2. Description of Action:

Nature: ☒ New Requirement ☐ Follow-on Requirement

Contract Vehicle: ☐ Purchase Order Number

☐ Blanket Purchase Agreement (BPA) Number

☐ Order/BPA# against FSS Contract #

☐ Order # against Multiple Award IDIQ Contract

☐ Order # against a single award IDC Contract

☐ Modification # to existing PO/TO/DO/Call Order

Pricing/Contract Type: ☒ Fixed Price ☐ Time & Materials/Labor Hours

☐ Cost Reimbursable ☐ Hybrid

Funds: ☒ Operations & Maintenance, Army (OMA) ☐ Other Funds:

FY: 2025

Brand Name Buy: ☒ Yes ☐ No

3. Description of Services or Supplies:

The West Point Simulation Center has a requirement for a single, one-time purchase of 05the AceXR Virtual Reality (VR) Pistol Training Capability. The requirement is for a complete system including three (3) Ace Enterprise Kits with 2-year software licenses, twenty-seven (27) Meta Quest 3 VR headsets, twenty-two (22) AceXR SIG P320 non-firearm training replicas, five (5) AceXR Arctus training replicas, associated holsters, carrying cases, and business management software. The purpose is to expand simulated marksmanship training for United States Military Academy (USMA) Cadets.

4. Authority: Select the appropriate authority below:

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Control No: MICC-WP-2025-84<SAT

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☒ FAR 13.106-1(b)(1): For purchases not exceeding the simplified acquisition threshold

(SAT), only one source reasonably available, urgency, exclusive licensing agreements, brand name, or industrial mobilization.

5. Reasons for Authority Cited:

a. The AceXR Virtual Reality Pistol Training Capability is the only system on the market that can meet the Government's essential requirement for a safe, accessible, and realistic marksmanship trainer. The critical, salient characteristic that no other system offers is its high-fidelity, non-firearm replica of the SIG SAUER P320 (the military's M17 service pistol). This feature is essential for USMA to conduct realistic dry-fire training that directly translates to live-fire qualification and competitive shooting events.

b. Market research confirmed that alternative systems are exclusively "drop-in kits," which require a user to pair a live, functional weapon with a firing mechanism.

This is unacceptable for the Government's use-case, as it would necessitate stringent firearm controls, preventing the on-demand, widespread access required for Cadet training across the Academy. The AceXR system utilizes a full, 3D-printed plastic dummy pistol that authentically matches the ergonomics, weight, and trigger feel of the M17, allowing it to be checked out and used safely in various locations. This capability is unique to the AceXR brand and is indispensable for meeting the training objectives.

c. Impact if not awarded: Failure to acquire the AceXR system will increase costs for weapons training, and render a major prior investment ineffective. In the absence of an effective VR simulator, USMA would be forced to rely on live-fire training. Furthermore, USMA has invested over $1.3 million in developing the West Point Simulation Center, including over $100,000 in supporting VR equipment (computers, headsets, etc.). Without an interface like the AceXR trainer, this highly advanced facility will be missing a portion of the critical hands-on military training it was designed for, thereby compromising the mission to develop military proficient Platoon Leaders and US Army Officers.

6. Publicizing Contract Actions: For FAR Part 13 actions, the public display and synopsis requirements of FAR 5.101 and FAR 5.203 ☐ do not apply due to the threshold, ☒ apply and will be followed, or ☐ do not apply due to an exception at FAR

5.202 .

Requirement to post justification in accordance with FAR 8.405-6(b)(3), FAR 13.105(c), or FAR 16.505(a)(4)(iii)(A) unless:

☐ Action is NOT a brand name restriction and is under $250K, no posting required.

☐ Action is a brand name restriction, under $25K, no posting required.

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Control No: MICC-WP-2025-84<SAT

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☒ Action is a brand name restriction, over . It will be redacted and posted with the solicitation.

☐ Action is a brand name restriction over but will not be posted due to the following exception:

☐ FAR 6.305(f)

☐ FAR 8.405-6(b)(3)(ii)(A)

☐ FAR 8.405-6(b)(3)(ii)(B)

☐ FAR 8.405-6(b)(3)(ii)(C)

☐ FAR 16.505(a)(4)(iii)(C)

7. Market Research: Market research was conducted in July 2025 by subject matter experts at the West Point Simulation Center (WPSC), the Combat Weapons Team, and the Department of Military Instruction (DMI) Vanguard program. The research involved hands-on testing of the AceXR system against peer systems. This research concluded that alternatives exclusively feature "drop-in kits" that require live weapons, which is an unacceptable solution due to safety and access constraints. The research confirmed that the AceXR system is the only product on the market that provides a realistic, non-firearm replica of the M17 service pistol necessary for the required training, making it the only brand that can meet the agency's needs.

8. Other Facts: There is no past procurement for this product.

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Control No: MICC-WP-2025-84<SAT

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9. Technical/Requirements Certification: I certify that the supporting data under my cognizance which are included in the justification are accurate and complete to the best of my knowledge and belief.

10. Contracting Officer Certification/Approval:

I hereby determine that the anticipated cost or price to the Government for this contract action will be fair and reasonable based upon Price Analysis.

I certify that this justification is accurate and complete to the best of my knowledge and belief, and that completing this purchase as a sole source is in the best interest of the Government. Additionally, I approve this justification to limit competition subject to the availability of funds and provided that the services or supplies herein described have otherwise been authorized for acquisition.