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Section 889 Representation — FAR 52.204-25
Repository: szl-holdings/a11oy
Entity: SZL Holdings
Date: 2026-06-01
This representation accompanies the SZL Holdings governed agentic mesh (Doctrine v11 LOCKED 749/14/163, sovereign-default). It implements the prohibition of FY2019 NDAA §889 as set out in FAR 52.204-25.
FAR 52.204-25 — Prohibition on Contracting for Certain Telecommunications and Video Surveillance Services or Equipment (verbatim representation text)
(a) Definitions. As used in this clause —
Backhaul, covered telecommunications equipment or services, critical technology, interconnection arrangements, reasonable inquiry, roaming, and substantial or essential component have the meanings provided in the clause 52.204-25, Prohibition on Contracting for Certain Telecommunications and Video Surveillance Services or Equipment.
(b) Prohibition. (1) Section 889(a)(1)(A) of the John S. McCain National Defense Authorization Act for Fiscal Year 2019 (Pub. L. 115-232) prohibits the head of an executive agency on or after August 13, 2019, from procuring or obtaining, or extending or renewing a contract to procure or obtain, any equipment, system, or service that uses covered telecommunications equipment or services as a substantial or essential component of any system, or as critical technology as part of any system. The Contractor is prohibited from providing to the Government any equipment, system, or service that uses covered telecommunications equipment or services as a substantial or essential component of any system, or as critical technology as part of any system, unless an exception at paragraph (c) of this clause applies or the covered telecommunication equipment or services are covered by a waiver described in FAR 4.2104.
(2) Section 889(a)(1)(B) of the John S. McCain National Defense Authorization Act for Fiscal Year 2019 (Pub. L. 115-232) prohibits the head of an executive agency on or after August 13, 2020, from entering into a contract, or extending or renewing a contract, with an entity that uses any equipment, system, or service that uses covered telecommunications equipment or services as a substantial or essential component of any system, or as critical technology as part of any system, unless an exception at paragraph (c) of this clause applies or the covered telecommunication equipment or services are covered by a waiver described in FAR 4.2104. This prohibition applies to the use of covered telecommunications equipment or services, regardless of whether that use is in performance of work under a Federal contract.
Representation (FAR 52.204-26 / SAM.gov)
SZL Holdings does NOT provide or use covered telecommunications equipment or services from: Huawei, ZTE, Hytera, Hikvision, Dahua, or their subsidiaries or affiliates — as a substantial or essential component of any system, or as critical technology as part of any system.
- The agentic mesh runs on mainstream commercial cloud / CNCF-certified Kubernetes (k3s/RKE2) and air-gapped single-node hardware. None of the build, runtime, or development bench incorporates covered equipment.
- No Huawei/ZTE telecommunications gear; no Hikvision/Dahua video-surveillance equipment; no Hytera radios are used as components.
- Per FAR, any covered item discovered during performance will be reported to the contracting officer within one (1) business day.
Attestation
Signed by:
Stephen P. Lutar Jr. Founder, SZL Holdings ORCID 0009-0001-0110-4173 Date: 2026-06-01
Signature on file (DCO-signed commit; founder e-signature to be applied at award per FAR 52.204-25 representation procedure).
Doctrine v11 LOCKED 749/14/163 · Λ Conjecture 1 · sovereign-default. Cosign fingerprint
b066de4081a3a49dd98d830ee68938facb86ffa5a658e71ddfe27b00b00f5dd2.