PART 1804
ADMINISTRATIVE
MATTERS
TABLE
OF CONTENTS
SUBPART 1804.1 CONTRACT
EXECUTION
1804.103 Contract
clause.
1804.170 Contract
effective date.
SUBPART 1804.2 CONTRACT DISTRIBUTION
1804.202 Agency
distribution requirements.
1804.203 Taxpayer
identification information.
SUBPART 1804.4 SAFEGUARDING CLASSIFIED INFORMATION WITHIN
INDUSTRY
1804.402 General.
1804.404-70 Contract clause.
1804.470 Security requirements for
unclassified information technology
(IT) resources
1804.470-1 Scope.
1804.470-2 Policy.
1804.470-3 IT
Security Requirements.
1804.470-4 Contract
clauses.
SUBPART 1804.5 ELECTRONIC COMMERCE IN CONTRACTING
1804.570 NASA
Acquisition Internet Service (NAIS).
1804.570-1 General.
1804.570-2 Electronic Posting System.
SUBPART 1804.6 CONTRACT REPORTING
1804.601 Record
requirements.
1804.604
Responsibilities.
1804.671
Committee on
Academic Science and Engineering (C.A.S.E.) Report.
SUBPART 1804.8 GOVERNMENT CONTRACT FILES
1804.802-70 Handling of classified material.
1804.803 Contents
of contract files.
1804.803-70 Checklist.
1804.804 Closeout
of contract files.
1804.804-2 Closeout of the contracting office files if another office
administers
the contract.
1804.804-5 Procedures for closing out contract
files.
1804.805 Storage,
handling, and disposal of contract files.
1804.805-70 Review, separation, and retirement of
contract files.
SUBPART 1804.9 TAXPAYER IDENTIFICATION NUMBER
1804.904 Reporting payment information to the IRS.
SUBPART 1804.70 TRANSFER
OF CONTRACTING OFFICE
RESPONSIBILITY
1804.7000 Scope
of subpart.
1804.7001 Definition.
1804.7002 Approval
of Transfer Requests.
1804.7003 Responsibilities
of the contracting officer of the transferring
installation.
1804.7003-1 Coordinations.
1804.7003-2 File inventory.
1804.7003-3 Notifications.
1804.7003-4 Transfer.
1804.7003-5 Retention documentation.
1804.7004 Responsibilities
of the contracting officer of the receiving
installation.
1804.7004-1 Pre-transfer file review.
1804.7004-2 Post-transfer actions.
SUBPART 1804.71 UNIFORM
ACQUISITION INSTRUMENT
IDENTIFICATION
1804.7100 Scope
of subpart.
1804.7101 Policy.
1804.7102 Numbering
scheme for solicitations.
1804.7103 Numbering
scheme for contracts.
1804.7104 Modifications
of contracts or agreements.
SUBPART 1804.72 REVIEW AND APPROVAL OF CONTRACTUAL
INSTRUMENTS
1804.7200 Contract
review by Headquarters.
SUBPART 1804.73
PROCUREMENT REQUESTS
1804.7301 General.
PART 1804
ADMINISTRATIVE
MATTERS
Subpart 1804.1--Contract Execution
1804.103
Contract clause.
The
contracting officer shall include the clause at FAR 52.204-1, Approval of Contract, in
solicitations, contracts, and supplemental agreements that require higher level
approval. For actions requiring
Headquarters approval, insert "NASA Assistant Administrator for
Procurement" in the clause's blank space.
1804.170
Contract effective date.
(a) "Contract
effective date" means the date agreed upon by the parties for
beginning the period of performance under the contract. In no case shall the effective date precede
the date on which the contracting officer or designated higher approval
authority signs the document.
(b) Costs incurred before the contract effective
date are unallowable unless they qualify as precontract costs (see FAR 31.205-32) and the clause prescribed at 1831.205-70 is used.
Subpart 1804.2--Contract Distribution
1804.202 Agency distribution requirements.
In addition to the requirements in FAR
4.201, the contracting officer shall distribute one
copy of each R&D contract, including the Statement of Work, to the NASA Center
for AeroSpace Information (CASI), Attention: Acquisitions Collections
Development Specialist, 7115
Standard Drive, Hanover, MD 21076-1320.
1804.203 Taxpayer identification information.
Instead
of using the last page of the contract to provide the information listed in FAR
4.203, NASA installations may allow contracting officers to use a different
distribution method, such as annotating the cover page of the payment office
copy of the contract.
Subpart 1804.4--Safeguarding
Classified Information Within Industry
1804.402 General.
(b) NASA security policies and procedures are prescribed in NPD 1600.2,
NASA Security Policy; NPR 1620.2, Physical Security Vulnerability Risk
Assessments; NPR 2810.1 Security of Information Technology; and NPD 2810.1,
NASA Information Security Policy.
1804.404-70 Contract
clause.
The
contracting officer shall insert the clause at 1852.204-75, Security Classification Requirements, in solicitations
and contracts if work to be performed will require security clearances. This clause may be modified to add
instructions for obtaining security clearances and access to security areas
that are applicable to the particular acquisition and installation.
1804.470 Security
requirements for unclassified information technology (IT) resources.
1804.470-1 Scope.
This section implements NASA's acquisition
requirements pertaining to Federal policies for the security of unclassified
information and information systems.
Federal policies include the Federal Information System Management Act
(FISMA) of 2002, Homeland Security Presidential Directive (HSPD) 12,
Clinger-Cohen Act of 1996 (40 U.S.C. 1401 et seq.), OMB Circular A-130,
Management of Federal Information Resources, and the National Institute of
Standards and Technology (NIST) security requirements and standards. These requirements safeguard IT services
provided to NASA such as the management, operation, maintenance, development,
and administration of hardware, software, firmware, computer systems, networks,
and telecommunications systems.
1804.470-2 Policy.
NASA IT security policies and procedures for
unclassified information and IT are prescribed in NASA Policy Directive (NPD) 2810,
Security of Information Technology; NASA Procedural Requirements (NPR) 2810,
Security of Information Technology; and interim policy updates in the form of
NASA Information Technology Requirements (NITR). IT services must be performed in accordance
with these policies and procedures.
1804.470-3 IT
Security Requirements.
These IT security requirements cover all NASA
contracts in which IT plays a role in the provisioning of services or products
(e.g., research and development, engineering, manufacturing, IT outsourcing,
human resources, and finance) that support NASA in meeting its institutional
and mission objectives. These
requirements are applicable where a contractor or subcontractor must obtain
physical or electronic (i.e., authentication level 2 and above as defined in
NIST Special Publication 800-63, Electronic Authentication Guideline) access to
NASA's computer systems, networks, or IT infrastructure. These requirements are also applicable in
cases where information categorized as low, moderate, or high by the Federal
Information Processing Standards (FIPS) 199, Standards for Security
Categorization of Federal Information and Information Systems, is stored,
generated, processed, or exchanged by NASA or on behalf of NASA by a contractor
or subcontractor, regardless of whether the information resides on a NASA or a
contractor/subcontractor’s information system.
1804.470-4
Contract clause.
(a) Insert the clause at 1852.204-76,
Security Requirements for Unclassified Information Technology Resources, in all
solicitations and contracts when contract performance requires contractors to
--
(1) Have physical or electronic access to
NASA's computer systems, networks, or IT infrastructure; or
(2) Use information systems to generate,
store, process, or exchange data with NASA or on behalf of NASA, regardless of
whether the data resides on a NASA or a contractor’s information system.
(b)
Paragraph (d) of the clause allows contracting officers to waive the
requirements of paragraphs (b) and (c)(1) through (3) of the clause. Contracting officers must obtain the approval
of the --
(1)
Center IT Security Manager before granting any waivers to paragraph (b)
of the clause; and
(2)
The Center Chief of Security before granting any waivers to paragraphs
(c)(1) through (3) of the clause.
(4) The NFS matrix may be reproduced by field installations for the
purpose of supplementing it with installation-developed provisions and clauses.
1852.103
Identification of provisions and clauses.
(b) Provisions and clauses prescribed by a field installation to satisfy
its needs shall be identified as stated in paragraphs (b)(i) and (ii) of this
section. Articles, formats, and similar
language shall be treated as provisions and clauses for purposes of this
section 1852.103.
(i) A provision or clause
shall be numbered using a prefix, a base, and a suffix. The prefix shall be an alphabetical
abbreviation of the installation name (e.g., ARC, DFRC, GRC, GSFC, JSC, KSC,
LARC, MSFC, SSC, or SSPO). The base
shall be a numeric value beginning with "52.2," with the next two
digits corresponding to the number of the FAR or NFS subject part to which the
provision or clause relates. The suffix
shall be a hyphen and sequential number assigned within each part. NASA installations shall use suffix numbers
from -90 to -199. For example, the first
Johnson Space Center (JSC) provision or clause relating to Part 36 of the FAR
or NFS shall be JSC 52.236-90, the second JSC 52.236-91, and so forth. Provisions and clauses shall be dated in
accordance with FAR 52.101(f).
(ii) Contracting officers
shall identify provisions and clauses as in the following examples:
(A) I.2 BID ENVELOPES (GSFC
52.214-90) (AUGUST 1987) This example is applicable when identifying
the title of provisions and clauses in solicitations and contracts using the
uniform contract format (UCF). The first
number ("I.2") designates the UCF section and the sequential clause
within that section. "GSFC
52.214-90" specifies the clause number.
(B) GSFC 52.214-90--Bid Envelopes
(AUGUST 1987) This example is applicable in all instances in which the
provision or clause citation is not associated with the UCF number.
(c) Contracting officers shall not number provisions and clauses
developed for individual acquisitions only.
For example, "F.3 Delivery Procedures for Special Hardware"
cites the third clause in Section F of a contract using the UCF, but has no
clause number or date identified with it, indicating that the clause was
developed for the particular contract it appears in.
1852.103-70
Identification of modified provisions and clauses.
When a FAR clause or provision is included in a solicitation or contract
and the NFS prescribes a modification, the title line shall identify the
modification as shown below. This format shall be used both for incorporation
by reference and when using full text.
"52.232-28
Electronic Funds Transfer Payment Methods (APR 1989)--as modified by NASA FAR
Supplement 1832.908(a)"
1852.104
Procedures for modifying and completing provisions and clauses.
NFS provisions and clauses shall not be modified unless authorized by
the NFS. When authorized, contracting
officers must comply with the procedures in FAR 52.104.
Subpart 1852.2--Text of Provisions and Clauses
1852.203-70 Display of Inspector General Hotline Posters.
As prescribed in 1803.7001, insert the following clause:
DISPLAY
OF INSPECTOR GENERAL HOTLINE POSTERS
(JUNE
2001)
(a) The Contractor shall display
prominently in common work areas within business segments performing work under
this contract, Inspector General Hotline Posters available under paragraph (b)
of this clause.
(b) Inspector General Hotline Posters may be obtained from NASA Office
of Inspector General, Code W, Washington,
DC, 20546-0001,
(202) 358-1220.
(End
of clause)
1852.204-75
Security Classification Requirements.
As prescribed in 1804.404-70, insert the following clause:
SECURITY CLASSIFICATION
REQUIREMENTS
(SEPTEMBER
1989)
Performance under this contract will involve access to and/or generation
of classified information, work in a security area, or both, up to the level of
[insert the applicable security clearance level]. See Federal Acquisition Regulation clause 52.204-2 in this contract and DD Form
254, Contract Security Classification Specification, Attachment
[Insert the attachment number of the DD Form 254].
(End
of clause)
1852.204-76
Security Requirements for Unclassified Information Technology Resources.
As prescribed in 1804.470-4(a), insert the
following clause:
SECURITY REQUIREMENTS FOR
UNCLASSIFIED INFORMATION TECHNOLOGY RESOURCES
(MAY 2007)
(a)
The Contractor shall be responsible for information and information
technology (IT) security when –
(1) The Contractor or its subcontractors
must obtain physical or electronic (i.e., authentication level 2 and above as
defined in National Institute
of Standards and
Technology (NIST) Special Publication (SP) 800-63, Electronic Authentication
Guideline) access to NASA's computer systems, networks, or IT infrastructure;
or
(2) Information categorized as low,
moderate, or high by the Federal Information Processing Standards (FIPS) 199,
Standards for Security Categorization of Federal Information and Information
Systems is stored, generated, processed, or exchanged by NASA or on behalf of
NASA by a contractor or subcontractor, regardless of whether the information
resides on a NASA or a contractor/subcontractor’s information system.
(b) IT
Security Requirements.
(1)
Within 30 days after contract award, a Contractor shall submit to the
Contracting Officer for NASA approval an IT Security Plan, Risk Assessment, and
FIPS 199, Standards for Security Categorization of Federal Information and
Information Systems, Assessment. These
plans and assessments, including annual updates shall be incorporated into the
contract as compliance documents.
(i) The IT system security plan shall
be prepared consistent, in form and content, with NIST SP 800-18, Guide for
Developing Security Plans for Federal Information Systems, and any
additions/augmentations described in NASA Procedural Requirements (NPR) 2810,
Security of Information Technology. The
security plan shall identify and document appropriate IT security controls
consistent with the sensitivity of the information and the requirements of
Federal Information Processing Standards (FIPS) 200, Recommended Security
Controls for Federal Information Systems.
The plan shall be reviewed and updated in accordance with NIST SP
800-26, Security Self-Assessment Guide for Information Technology Systems, and
FIPS 200, on a yearly basis.
(ii)
The risk assessment shall be prepared consistent, in form and content,
with NIST SP 800-30, Risk Management Guide for Information Technology Systems,
and any additions/augmentations described in NPR 2810. The risk assessment shall be updated on a
yearly basis.
(iii) The FIPS 199 assessment shall identify all
information types as well as the “high water mark,” as defined in FIPS 199, of
the processed, stored, or transmitted information necessary to fulfill the
contractual requirements.
(2)
The Contractor shall produce contingency plans consistent, in form and
content, with NIST SP 800-34, Contingency Planning Guide for Information
Technology Systems, and any additions/augmentations described in NPR 2810. The Contractor shall perform yearly
“Classroom Exercises.” “Functional Exercises,” shall be coordinated with the
Center CIOs and be conducted once every three years, with the first conducted
within the first two years of contract award.
These exercises are defined and described in NIST SP 800-34.
(3)
The Contractor shall ensure coordination of its incident response team
with the NASA Incident Response Center (NASIRC) and the NASA Security
Operations Center, ensuring that incidents are reported consistent with NIST SP
800-61, Computer Security Incident Reporting Guide, and the United States
Computer Emergency Readiness Team’s (US-CERT) Concept of Operations for
reporting security incidents.
Specifically, any confirmed incident of a system containing NASA data or
controlling NASA assets shall be reported to NASIRC within one hour that
results in unauthorized access, loss or modification of NASA data, or denial of
service affecting the availability of NASA data.
(4) The Contractor shall ensure that its
employees, in performance of the contract, receive annual IT security training
in NASA IT Security policies, procedures, computer ethics, and best practices
in accordance with NPR 2810 requirements.
The Contractor may use web-based training available from NASA to meet
this requirement.
(5) The Contractor shall provide NASA,
including the NASA Office of Inspector General, access to the Contractor’s and
subcontractors’ facilities, installations, operations, documentation,
databases, and personnel used in performance of the contract. Access shall be
provided to the extent required to carry out IT security inspection,
investigation, and/or audits to safeguard against threats and hazards to the
integrity, availability, and confidentiality of NASA information or to the
function of computer systems operated on behalf of NASA, and to preserve
evidence of computer crime. To
facilitate mandatory reviews, the Contractor shall ensure appropriate
compartmentalization of NASA information, stored and/or processed, either by
information systems in direct support of the contract or that are incidental to
the contract.
(6)
The Contractor shall ensure that system administrators who perform tasks
that have a material impact on IT security and operations demonstrate knowledge
appropriate to those tasks. Knowledge is demonstrated through the NASA System
Administrator Security Certification Program.
A system administrator is one who provides IT services (including
network services, file storage, and/or web services) to someone other than
themselves and takes or assumes the responsibility for the security and
administrative controls of that service.
Within 30 days after contract award, the Contractor shall provide to the
Contracting Officer a list of all system administrator positions and personnel
filling those positions, along with a schedule that ensures certification of all
personnel within 90 days after contract award.
Additionally, the Contractor should report all personnel changes which
impact system administrator positions within 5 days of the personnel change and
ensure these individuals obtain System Administrator certification within 90
days after the change.
(7) The Contractor shall ensure that
NASA’s Sensitive But Unclassified (SBU) information as defined in NPR 1600.1,
NASA Security Program Procedural Requirements, which includes privacy
information, is encrypted in storage and transmission.
(8) When the Contractor is located at a NASA Center
or installation or is using NASA IP address space, the Contractor shall --
(i) Submit requests for non-NASA
provided external Internet connections to the Contracting Officer for approval
by the Network Security Configuration Control Board (NSCCB);
(ii) Comply with the NASA CIO
metrics including patch management, operating systems and application
configuration guidelines, vulnerability scanning, incident reporting, system
administrator certification, and security training; and
(iii) Utilize the NASA Public Key Infrastructure
(PKI) for all encrypted communication or non-repudiation requirements within
NASA when secure email capability is required.
(c) Physical and Logical Access Requirements.
(1) Contractor personnel requiring access
to IT systems operated by the Contractor for NASA or interconnected to a NASA
network shall be screened at an appropriate level in accordance with NPR 2810
and Chapter 4, NPR 1600.1, NASA Security Program Procedural Requirements. NASA shall provide screening, appropriate to
the highest risk level, of the IT systems and information accessed, using, as a
minimum, National Agency Check with Inquiries (NACI). The Contractor shall submit
the required forms to the NASA
Center Chief of Security
(CCS) within fourteen (14) days after contract award or assignment of an
individual to a position requiring screening.
The forms may be obtained from the CCS.
At the option of NASA, interim access may be granted pending completion
of the required investigation and final access determination. For Contractors who will reside on a NASA Center
or installation, the security screening required for all required access (e.g.,
installation, facility, IT, information, etc.) is consolidated to ensure only
one investigation is conducted based on the highest risk level. Contractors not residing on a NASA
installation will be screened based on their IT access risk level determination
only. See NPR 1600.1, Chapter 4.
(2) Guidance for selecting the
appropriate level of screening is based on the risk of adverse impact to NASA
missions. NASA defines three levels of
risk for which screening is required (IT-1 has the highest level of risk).
(i)
IT-1 -- Individuals having privileged access or limited privileged
access to systems whose misuse can cause very serious adverse impact to NASA
missions. These systems include, for
example, those that can transmit commands directly modifying the behavior of
spacecraft, satellites or aircraft.
(ii) IT-2 -- Individuals having
privileged access or limited privileged access to systems whose misuse can
cause serious adverse impact to NASA missions.
These systems include, for example, those that can transmit commands
directly modifying the behavior of payloads on spacecraft, satellites or
aircraft; and those that contain the primary copy of “level 1” information
whose cost to replace exceeds one million dollars.
(iii) IT-3 -- Individuals having
privileged access or limited privileged access to systems whose misuse can
cause significant adverse impact to NASA missions. These systems include, for example, those
that interconnect with a NASA network in a way that exceeds access by the
general public, such as bypassing firewalls; and systems operated by the
Contractor for NASA whose function or information has substantial cost to
replace, even if these systems are not interconnected with a NASA network.
(3)
Screening for individuals shall employ forms appropriate for the level
of risk as established in Chapter 4, NPR 1600.1.
(4)
The Contractor may conduct its own screening of individuals requiring
privileged access or limited privileged access provided the Contractor can
demonstrate to the Contracting Officer that the procedures used by the
Contractor are equivalent to NASA's personnel screening procedures for the risk
level assigned for the IT position.
(5) Subject to approval of the
Contracting Officer, the Contractor may forgo screening of Contractor personnel
for those individuals who have proof of a --
(i) Current or recent national
security clearances (within last three years);
(ii) Screening conducted by NASA
within the last three years that meets or exceeds the screening requirements of
the IT position; or
(iii) Screening conducted by the
Contractor, within the last three years, that is equivalent to the NASA
personnel screening procedures as approved by the Contracting Officer and
concurred on by the CCS.
(d)
The Contracting Officer may waive the requirements of paragraphs (b) and
(c)(1) through (c)(3) upon request of the Contractor. The Contractor shall provide all relevant
information requested by the Contracting Officer to support the waiver request.
(e)
The Contractor shall contact the Contracting Officer for any documents,
information, or forms necessary to comply with the requirements of this clause.
(f) At
the completion of the contract, the contractor shall return all NASA
information and IT resources provided to the contractor during the performance
of the contract and certify that all NASA information has been purged from
contractor-owned systems used in the performance of the contract.
(g)
The Contractor shall insert this clause, including this paragraph (g),
in all subcontracts
(1) Have physical or electronic access to
NASA's computer systems, networks, or IT infrastructure; or
(2) Use information systems to generate,
store, process, or exchange data with NASA or on behalf of NASA, regardless of
whether the data resides on a NASA or a contractor’s information system.
(End of clause)
1852.208-81 Restrictions on Printing and
Duplicating.
As prescribed in 1808.870, insert the following clause:
RESTRICTIONS ON
PRINTING AND DUPLICATING
(NOVEMBER
2004)
(a) The Contractor may duplicate or copy any documentation required by
this contract in accordance with the provisions of the Government Printing and
Binding Regulations, No. 26, S. Pub 101-9, U.S. Government Printing Office, Washington, DC, 20402, published by the Joint Committee on Printing, U.S.
Congress.
(b) The Contractor shall not perform, or procure from any commercial
source, any printing in connection with the performance of work under this
contract. The term "printing"
includes the processes of composition, platemaking, presswork, duplicating,
silk screen processes, binding, microform, and the end items of such processes
and equipment.
(c) The Contractor is authorized to duplicate or copy production units
provided the requirement does not exceed 5,000 production units of any one page
or 25,000 units in the aggregate of multiple pages. Such pages may not exceed a maximum image
size of 10-3/4 by 14-1/4 inches. A
"production unit" is one sheet, size 8-1/2 x 11 inches (215 x 280
mm), one side only, and one color ink.
(d)
This clause does not preclude writing, editing, preparation of manuscript copy,
or preparation of related illustrative material as a part of this contract, or
administrative duplicating/copying (for example, necessary forms and
instructional materials used by the Contractor to respond to the terms of the
contract).
(e) Costs associated with printing, duplicating, or copying in excess of
the limits in paragraph (c) of this clause are unallowable without prior
written approval of the Contracting Officer.
If the Contractor has reason to believe that any activity required in
fulfillment of the contract will necessitate any printing or substantial
duplicating or copying, it immediately shall provide written notice to the
Contracting Officer and request approval prior to proceeding with the
activity. Requests will be processed by
the Contracting Officer in accordance with the provisions of the Government
Printing and Binding Regulations, NFS 1808.802, and NPR 1490.5, NASA Procedural
Requirements for Printing, Duplicating, and Copying Management.
(f) The Contractor shall include in each subcontract which may involve a
requirement for any printing, duplicating, and copying in excess of the limits
specified in paragraph (c) of this clause, a provision substantially the same
as this clause, including this paragraph (f).
(End
of clause)
1852.209-70
Product Removal from Qualified Products List.
As prescribed in 1809.206-71, insert the following clause:
PRODUCT REMOVAL FROM
QUALIFIED PRODUCTS LIST
(DECEMBER
1988)
If, during the performance of this contract, the product being furnished
is removed from the Qualified Products List for any reason, the Government may
terminate the contract for Default pursuant to the default clause of the
contract.
(End
of clause)
1852.209-71
Limitation of Future Contracting.
As prescribed in 1809.507-2, the contracting officer may insert a clause
substantially as follows in solicitations and contracts, in compliance with FAR 9.507-2:
LIMITATION
OF FUTURE CONTRACTING
(DECEMBER
1988)
(a) The Contracting Officer has determined that this acquisition may
give rise to a potential organizational conflict of interest. Accordingly, the attention of prospective offerors
is invited to FAR Subpart 9.5--Organizational
Conflicts of Interest.
(b) The nature of this conflict is [describe the conflict].
(c) The restrictions upon future contracting are as follows:
(1) If the Contractor, under the terms of this contract, or through the
performance of tasks pursuant to this contract, is required to develop
specifications or statements of work that are to be incorporated into a
solicitation, the Contractor shall be ineligible to perform the work described
in that solicitation as a prime or first-tier subcontractor under an ensuing NASA
contract. This restriction shall remain in effect for a
reasonable time, as agreed to by the Contracting Officer and the Contractor,
sufficient to avoid unfair competitive advantage or potential bias (this time
shall in no case be less than the duration of the initial production
contract). NASA shall not unilaterally
require the Contractor to prepare such specifications or statements of work
under this contract.
(2) To the extent that the work under this contract requires access to
proprietary, business confidential, or financial data of other companies, and
as long as these data remain proprietary or confidential, the Contractor shall
protect these data from unauthorized use and disclosure and agrees not to use
them to compete with those other companies.
(End
of clause)
