Comment on FR Doc # 2026-12205
Trilogy Innovations, Inc.SupportBusiness
Summary: Trilogy Innovations, Inc., an SBA 8(a)-certified federal IT small business, supports the core objectives of the proposed GSAR clause regarding the safeguarding of data within LLM systems. However, they argue for specific revisions to address technical infeasibilities (such as data deletion from fine-tuned models), clarify incident notification timelines for supply chains, and reduce the administrative burden on small businesses through consolidated compliance paths.
Trilogy Innovations, Inc. submits the attached formal comment in response to Notice-MVAC-2026-01, Docket No. 2026-0331, regarding proposed GSAR clause 552.239-7001, Basic Safeguarding of Data Within Large Language Model Artificial Intelligence Systems.
Trilogy is an SBA 8(a)-certified federal IT small business operating as a mission-aligned systems integrator across HHS, DHS, DOJ/FBI, DoD, and DOE. Our comments address six specific implementation concerns with the proposed clause: the multi-role flowdown compliance burden for small business primes, the 72-hour incident notification clock as applied to third-party supply chains, the model version change requirement for commercial API-based LLM deployments, due process protections in the Unbiased AI benchmarking framework, the technical infeasibility of fine-tuned model data deletion, and small business compliance scaling. Each comment is cited to the specific paragraph of the proposed clause and includes suggested alternative language.
We respectfully request the opportunity to present these comments at the July 14, 2026 Listening Session under the Clause Flowdown Requirements category.
Notice-MVAC-2026-01 | Trilogy Innovations, Inc. |
Bill McKenna, Chief Growth Officer | bill.mckenna@trilogyit.com | (703) 489-4053