Redacted_RFO MFR_Limiting Competition under SAT_W9124J-26-P-A012_Redacted.pdf

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W9124J-26-Q-CHMU
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This is a Memorandum for Record documenting a sole source procurement justification for a non-competitive contract award below the Simplified Acquisition Threshold.

The Installation Management Command (IMCOM) Religious Support Office seeks approval to award a new $164,197.63 firm-fixed-price (FFP) follow-on contract to Christian Copyright Licensing International, LLC (CCLI) located in Vancouver, Washington for a five-year period (base year plus four one-year options) using FY 2026 Operations and Maintenance, Army funds. The contract will provide SongSelect Advanced Music Subscription and Christian Music Licensing services, enabling the Government to legally store, reproduce, distribute, publicly display, and perform digitally transmitted sound recordings in support of military religious and worship activities. The procurement authority cited is FAR 12.201-1 for commercial acquisitions at or below the simplified acquisition threshold and FAR 16.507-6(b)(2) for the exception to fair opportunity based on only one awardee being capable of performing the requirement. Market research confirmed CCLI is the sole source capable of providing the unified solution combining streaming subscriptions, downloading capabilities, storage, reproduction, distribution, public display, and legal coverage for derivative works. The current contract (W9124J-21-P-0008) awarded to CCLI in 2021 for $142,077.66 expires June 13, 2026, and the contractor has performed satisfactorily. Failure to approve would prevent the Religious Support Office from legally using copyrighted music during worship services, adversely affecting 57 congregational worship services and creating copyright infringement risk.

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CUI//SP-PROCURE//FEDCON

recordings in support of military religious and worship activities. This service enables the Government to use SongSelect music and its lyrics in public settings, display lyrics, and perform other functions with the music.

Period of Performance:

5. Authority: Select the appropriate authority below:

FAR 12.201-1 For commercial acquisitions valued at or below the simplified acquisition threshold

Limiting Sources when Ordering under the Federal Supply Schedule GSAM 538.7104-3(b)(1)(i) - Urgency GSAM 538.7104-3(b)(1)(ii) - Only One Source is Capable GSAM 538.7104-3(b)(1)(iii) - Logical Follow-on GSAM 538.7104-3(b)(1) (iv) - Satisfy minimum guarantee GSAM 538.7104-3(b)(1) (v) - Authorized or required by statute GSAM 538.7104-4 - Items peculiar to one manufacturer

Exceptions to Fair Opportunity FAR 16.507-6(b)(1) - Unusual and urgent need FAR 16.507-6(b)(2) - Only One Awardee is Capable FAR 16.507-6(b)(3) - Logical Follow-on FAR 16.507-6(b)(4) - Minimum Guarantee FAR 16.507-6(b)(5) - Statute Authorizes / Requires Purchase from Specified Source FAR 16.507-6(b)(6) - Satisfies Exception under FAR 6.103 FAR 16.507-7 - Items peculiar to one manufacturer

6. Reasons for Authority Cited:

a. Background: This is a follow-on requirement. The current contract, W9124J-21- P-0008, was awarded as a Base Year with 4, 12-month Option Years. The current PoP is 14 June 25 – 13 June 26. The current contract was awarded to Christian Copyright Licensing International, LLC and the contractor has performed satisfactorily under the current contract.

CCLI is the only reasonable source that can provide the required supplies and licensing. The Government is currently using CCLI music subscriptions and licenses.

CCLI has no authorized retailers that sell its subscriptions or rights to sell the licensing it administers on behalf of various music labels. The Government has made a significant investment in its current inventory of religious music subscription; personnel are familiar with the website and capabilities.

b. Alternatives: To assess the competitive landscape, the Government conducted target market research of industry websites. While several providers offer music subscription services, none were found to offer a unified solution combining both subscriptions and licenses. Furthermore, the Government identified no competitors capable of providing licenses that support critical secondary requirements, including music storage, reproduction (e.g., recording/copying), distribution, public display/projection, or the creation of derivative works (e.g., arrangements or translations). Christian Copyright Licensing International, LLC is the only vendor that offers streaming music subscriptions, downloading (storage), manipulations, display, reproduction, and the requisite legal coverage.

c. Impact if not approved: If the justification is not approved, the IMCOM Religious

Support Office will be unable to legally use, display, or reproduce copyrighted religious music during worship services. This would force congregations to rely strictly on the limited scope of the Religious Service Exemption, severely degrading the quality and active participation of 57 congregational worship services and risking potential copyright infringement.

7. Publicizing Contract Actions:

a. The public display and synopsis requirements of FAR 5.101(a) and FAR 5.101(d) do not apply, less than $20K threshold apply and will be followed do not apply due to an exception at FAR 5.101(b)(1)( )

b. Requirement to post justification in accordance with, FAR 12.102(a)(2), GSAM

538.7104-3(a)(3) or FAR 16.507-6(f) unless:

Action is not a brand name restriction and is under SAT, no posting required.

Action is a brand name restriction, under $40K, no posting required.

Action is a brand name restriction over $40K but will not be posted due to the following exception:

FAR 6.301(e) GSAM 538.7104-3(b)(3)(i)(B) FAR 16.507-6(f)(4)

8. Market Research: The Government conducted Market Research IAW FAR Part 10 and DFARS 210.001. A Sources Sought Notice (SSN W9124J-26-Q-CHMU) was posted on SAM.gov from 14 May 2026 to 20 May 2026. One vendor (BHPE, LLC)

File details come from the government source that posted it. Updated .