W9115125PA032_MFR Limiting Competition Under SAT (KO signed)_Redacted.pdf

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

1. Contracting Activity: Mission and Installation Contracting Command Fort Hood (MICC-FH), 36000 Darnall Loop, Fort Cavazos, TX 76544-5025.

2. Description of Action:

Nature: ☒ New Requirement ☐ Follow-on Requirement

Contract Vehicle: ☒ Purchase Order Number PANMCC-25-P-0000 028948

☐ Blanket Purchase Agreement (BPA) Number

☐ Order/BPA# against FSS Contract #

☐ Order # against Multiple Award IDIQ Contract Name or #

☐ 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 Government requires the procurement of 15 Steel Beasts Professional software licenses with maintenance to enhance simulation training for 1st Cavalry Division (1CD).

The software will provide realistic vehicle, infantry, and combat simulations to support training readiness. This requirement is for commercial, market-ready software not available through CHESS or other mandatory sources. Licenses must be immediately available.

For Actions without Options:

Control No: Hood 2025-14

4. Authority: Select the appropriate authority below:

☒ 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.

Or, ☐ FAR 8.405-6(a)(1)(i)(A) Urgency ☐ FAR 8.405-6(a)(1)(i)(B) Only One Source is Capable

☐ FAR 8.405-6(a)(1)(i)(C) Logical Follow-on

☐ FAR 8.405-6(b)(1) Brand Name

Or, ☐ FAR 16.505(b)(2)(i)(A) Urgency

☐ FAR 16.505(b)(2)(i)(B) Only One Awardee is Capable

☐ FAR 16.505(b)(2)(i)(C) Logical Follow-on

☐ FAR 16.505(b)(2)(i)(D) Minimum Guarantee

☒ FAR 16.505(a)(4) Brand Name

5. Reasons for Authority Cited:

The requirement for simulation software to support 1st Cavalry Division 1CD training can only be satisfied by Steel Beasts Professional, developed and sold exclusively by eSim Games. Market research confirmed that no other vendor or product offers the integrated set of capabilities required by the Government, including multi-day exercise endurance, large-scale vehicle and operator support, robust instructor and AAR tools, detailed energy-based vulnerability modeling, dynamic terrain and engineering functions, integration of robotic and anti-drone systems, and realistic combined arms functionality. These features are essential to replicate operational conditions and provide the necessary training realism for armored and mechanized units. Steel Beasts Professional is a proprietary product, and eSim Games retains exclusive rights to its development and licensing. The company does not authorize resellers, and the software is not available through mandatory sources such as CHESS, AbilityOne, or Federal Supply Schedules. Additionally, Steel Beasts Professional is the recognized tool of choice among NATO partners for armored simulation training. Procuring this product ensures interoperability and alignment with multinational partners, strengthening the ability of 1CD to train and operate effectively in coalition environments. Based on these factors, eSim Games is the only responsible source capable of meeting the Government’s minimum requirements, and a sole source acquisition is the only viable method to obtain the needed licenses.

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 (a) 11.

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.

☒ Action is a brand name restriction, over $25K. It will be redacted and posted with the solicitation.

☐ Action is a brand name restriction over $25K 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 for this requirement was conducted during August 2025 by the undersigned contracting personnel in coordination with the 1CD, the requiring activity.

The research included a review of Government-wide mandatory sources such as AbilityOne, Federal Prison Industries, and CHESS, as well as open searches of GSA Advantage, SAM.gov, and commercial vendor listings. No comparable products were identified through these sources. In addition, product literature and vendor information were reviewed, and discussions were held with the requiring activity to confirm minimum needs and salient characteristics.

The results of the market research determined that Steel Beasts Professional, developed and licensed solely by eSim Games, is the only software capable of meeting the Government’s requirement. While other commercial simulation products exist, they do not offer the integrated set of features required, including multi-day exercise capability, detailed vulnerability modeling, dynamic terrain and engineering functions, and robust instructor and after-action review tools. These features are essential for the 1st Cavalry Division’s training environment and cannot be satisfied by other products without significant modification, which is not feasible. Accordingly, the market research supports a brand-name, sole source acquisition from eSim Games as the only responsible source able to meet the requirement.

8. Other Facts:

Not Applicable