REDACTED Sole Source Justification.pdf

Sole Source (Including Brand Name) Justification - Simplified Procedures for Certain Commercial Items

CONTROLLED UNCLASSIFIED INFORMATION

March 2023 CONTROLLED UNCLASSIFIED INFORMATION Page 1 of 5

NOTE: If a Justification was approved for the preceding acquisition, a copy of the approved Justification for the predecessor action must be included in the staff package for approval of the instant Justification. This applies to Justification staff packages that are submitted for review and approval at a level above the contracting officer. The predecessor Justification will be used as a reference document by the approving official.

Is this a new or amended J&A Document? New Amended ( Prior to Award Only! )

Is this a Bridge Action as defined in the AF Bridge Action Reduction Plan? Yes No

Funding level for this acquisition: >SAT and < $750K > $750K and < $15M

Contracting Activity: AFLCMC/PZITA

Purchase Request / Local ID Number:

Program / Project (and PE, if applicable): ABBYY Licenses

Program Type (PEO or Other Contracting): Other Contracting

Authority: AFFARS 5313.501 - 10 U.S.C. 3572, Implementation of Simplified Acquisition Procedures (41 U.S.C. 1901)

AFFARS 5313.501 - 10 U.S.C. 3403, Special Emergency Procurement Authority (41 U.S.C. 1903)

Estimated Contract Cost (including options): Justification Type: Class Individual

COORDINATION ( AFFARS 5306.304(a))

Date

Sole Source (Including Brand Name) Justification - Simplified Procedures for Certain Commercial Items

March 2023 CONTROLLED UNCLASSIFIED INFORMATION Page 2 of 5

I. Contracting Activity.

AFLCMC/PZITA

II. Nature and/or description of the action being processed.

The activity proposes to process a new, Firm-Fixed-Price (FFP) contract action for proprietary software subscription renewals and licenses. This action will be awarded as a new contract to ABBYY USA Software House Inc., located at

. The planned contract type is Firm-Fixed-Price, in accordance with FAR Part 12 (Acquisition of Commercial Products and Commercial Services) and FAR Part 13 (Simplified Acquisition Procedures). This is a new, one-time contract award and does not modify any existing contract. The total estimated value of this proposed action is

III. Description of supplies/services required to meet agency needs.

The has a requirement for the renewal and acquisition of proprietary ABBYY FineReader document processing software licenses and subscriptions. This software provides mission-critical optical character recognition (OCR) and high-volume document conversion capabilities to support foreign language intelligence analysis.The required items under this action, including quantities, part numbers, and estimated values, are detailed below:

Line Item 1: ABBYY FineReader Server License, Subscription, 1,200,000 Pages per Year (PPY) Brand Name: ABBYY Part/Model Number: FRS-S Quantity: 1

Line Item 2: ABBYY FineReader Server Production License, Subscription, 1,000,000 PPY Brand Name: ABBYY Part/Model Number: FRS-PROD-S

Line Item 3: ABBYY FineReader Server Language Add-on, Arabic

Part/Model Number: FRS-LAO-S

Line Item 4: ABBYY FineReader Server Language Add-on, CJK (Chinese, Japanese, Korean)

Part/Model Number: FRS-LAO-S

Line Item 5: ABBYY FineReader Server Development and Test System, Backup License, Subscription, 200,000 PPY

Part/Model Number: FRS-TEST-S

Sole Source (Including Brand Name) Justification - Simplified Procedures for Certain Commercial Items

March 2023 CONTROLLED UNCLASSIFIED INFORMATION Page 3 of 5

Line Item 6: ABBYY FineReader PDF Corporate, Volume License (per Seat), GOV/NPO/EDU, Subscription, 50 Workstations Brand Name: ABBYY Part/Model Number: FRCW-GBS

Total Estimated Acquisition Value:

The requirement will be funded utilizing . The entire period of performance is restricted to a single 12-month period There are no options, unpriced or otherwise, associated with this acquisition.

IV. Statutory authority permitting other than full and open competition.

AFFARS 5313.501 - 10 U.S.C. 3572, Implementation of Simplified Acquisition Procedures (41 U.S.C. 1901).

V. Demonstration that the contractor's unique qualifications or nature of the acquisition requires the use of the authority cited above (applicability of authority).

The requires proprietary renewal subscriptions and seat licenses for ABBYY FineReader software products. ABBYY USA Software House Inc. is the sole proprietary developer, intellectual property owner, and licensing authority for ABBYY software products in North America.

has integrated ABBYY FineReader Server and PDF Corporate technologies into its established intelligence production pipelines to automate the translation, OCR, and text-extraction of foreign language documents, including highly specialized Arabic and Chinese-Japanese-Korean (CJK) character sets. The software's specific algorithms and parsing engines are uniquely capable of handling the volume and complexity of the agency's document ingestion.

As confirmed in the direct certification letter from ABBYY USA Software House Inc., while standard application products may be distributed through certified resellers, direct enterprise and server licensing, including specialized co-terminated subscription renewals, are managed directly by ABBYY. For the purposes of this specialized Air Force requirement, ABBYY USA Software House Inc. has provided direct quote to co-terminate and renew specific server and workstation licenses.

Introducing any alternative OCR or document conversion solution would result in a severe, unacceptable disruption to ongoing intelligence analysis workflows. Replacing the ABBYY architecture would require extensive software re-development, API integration, and workstation re-imaging across secured networks. This would result in substantial duplication of costs that are not expected to be recovered through competition, as well as significant operational delays in critical reporting schedules. Accordingly, ABBYY USA Software House Inc. is the only source capable of providing the proprietary software licenses and renewal keys required to satisfy the government's need.

VI. Description of efforts made to ensure that offers are solicited from as many potential sources as practicable.

In accordance with FAR 5.2 and FAR 13.105, a notice of intent to sole source along with a combined synopsis/ solicitation will be posted to the Governmentwide Point of Entry (SAM.gov) to publicize this requirement. This notice will allow any potentially interested sources to submit capability statements demonstrating their ability to fulfill the requirement.

Any response received from potential sources will be thoroughly evaluated by technical and contracting teams. However, because these subscription renewals rely on proprietary licensing keys and software code owned exclusively by ABBYY USA Software House Inc., no other vendors are expected to have the legal right or technical

Sole Source (Including Brand Name) Justification - Simplified Procedures for Certain Commercial Items

March 2023 CONTROLLED UNCLASSIFIED INFORMATION Page 4 of 5 ability to provide the required software updates and direct subscription support.

VII. Determination by the Contracting Officer that the anticipated cost to the Government will be fair and reasonable.

The Contracting Officer will ensure that the final contract price is fair and reasonable. In accordance with FAR 13.106-3 and FAR 15.404-1, the anticipated price of will be evaluated using a detailed price analysis. This analysis will compare the pricing quoted under against commercial price lists, historical pricing paid by the Government for identical ABBYY licensing packages, and established commercial industry benchmarks.

Because this procurement is for commercial items under the Simplified Acquisition Threshold, certified cost or pricing data are not required. A thorough technical evaluation will be completed to verify that the items quoted perfectly match the technical specifications of the Bill of Materials. These steps will ensure that the Government receives the best possible value.

VIII. Description of the market research conducted and the results, or a statement of the reasons market research was not conducted.

Market research was conducted in accordance with FAR Part 10. The research team evaluated current commercial-off-the-shelf (COTS) optical character recognition (OCR) and document workflow automation products. While general-purpose OCR tools are commercially available, none offer direct, drop-in compatibility with existing automated document processing systems, nor do they support the specialized Arabic and CJK linguistic recognition rules integrated into customized server configurations.

Furthermore, historical acquisition files and the manufacturer's licensing declarations were reviewed. This research confirmed that ABBYY USA Software House Inc. maintains strict control over the proprietary source code, licensing structures, and activation mechanisms for the requested software products. As a result, no other commercial solutions or reseller channels can provide the required co-terminated renewal licenses without unacceptable risks of operational downtime and system failure.

IX. Any other facts supporting the use of Other Than Full and Open Competition.

The technical specifications, licensing structures, and internal source code of the ABBYY FineReader software suite are highly proprietary to ABBYY USA Software House Inc. The Government does not possess, and cannot acquire, the technical data packages, specifications, or software rights required to develop or permit a third party to generate subscription renewal keys or system updates. Consequently, it is legally and technically impossible to draft a competitive solicitation package that would allow other sources to fulfill this requirement.

X. List of any sources that expressed, in writing, an interest in the acquisition.

See Section VI above. No other sources have expressed interest in this acquisition to date.

XI. A statement of the actions, if any, the agency may take to remove or overcome any barriers to competition before making subsequent acquisitions for the supplies or services required.

will continue to query for commercially available hardware and software products of this kind to determine if the capabilities are able to meet the government's requirements. SMEs will also review

Sole Source (Including Brand Name) Justification - Simplified Procedures for Certain Commercial Items

March 2023 CONTROLLED UNCLASSIFIED INFORMATION Page 5 of 5 technical publications, expositions, trend guidelines, and Air Force regulations and instructions, as well as confer with other agencies and experts, so that future actions may be solicited under full and open competition procedures. All competing commercial products have been evaluated prior to submission of this requirement and none were deemed feasible for incorporation into current technical infrastructure.

As new trends formulate within production, will continue to inquire about these devices and research ways to develop, test, and integrate them if possible.

XII. Certification by the Contracting Officer.

As evidenced by my signature above, I have determined this document to be both accurate and complete to the best of my knowledge and belief.

XIII. Certification by the technical/requirements personnel.

As evidenced by my (our) signature(s) above, I (we) certify that any supporting data contained herein, which is my (our) responsibility, is both accurate and complete.