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| <!-- SPDX-License-Identifier: Apache-2.0 --> | |
| <!-- © 2026 Lutar, Stephen P. — SZL Holdings · ORCID 0009-0001-0110-4173 --> | |
| # 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)._ | |
| --- | |
| <sub>Doctrine v11 LOCKED 749/14/163 · Λ Conjecture 1 · sovereign-default. Cosign fingerprint | |
| `b066de4081a3a49dd98d830ee68938facb86ffa5a658e71ddfe27b00b00f5dd2`.</sub> | |