# 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`.}