{ "$schema": "https://schemas.nightboxllc.com/section-1260h-attestation/v1.json", "@context": "https://schema.org", "@type": "Dataset", "@id": "https://nightboxllc.com/.well-known/section-1260h-attestation.json", "name": "NIGHTBOX — Section 1260H Chinese Military Companies Non-Affiliation Attestation", "headline": "Self-attestation per Section 1260H of the William M. (Mac) Thornberry National Defense Authorization Act for Fiscal Year 2021 (Pub. L. No. 116-283, § 1260H) and the FY2024 NDAA expansion (Pub. L. No. 118-31, § 805) — NIGHTBOX LLC attests that it (a) is not listed on the DoD Section 1260H List of Chinese Military Companies, (b) is not controlled by any entity on that list, and (c) does not engage outside consultants who lobby on behalf of any entity on that list, anticipating the procurement-prohibition effective date of June 30, 2026.", "version": "1.0", "issued_date": "2026-05-16", "next_attestation_due": "2027-05-16", "license": "https://creativecommons.org/licenses/by/4.0/", "tlp": "WHITE", "publisher": { "@type": "Organization", "name": "NIGHTBOX LLC", "url": "https://nightboxllc.com/", "sam_uei": "UHCAB6UXXKF2", "ein": "39-4373044", "domicile": "Wyoming, United States" }, "attesting_official": { "name": "Artem Shakin", "title": "Sole Member, Founder, and Attesting Official", "email": "artem@nightboxllc.com" }, "regulatory_anchors": { "section_1260h_origin": { "citation": "Section 1260H of the William M. (Mac) Thornberry National Defense Authorization Act for Fiscal Year 2021 (Pub. L. No. 116-283)", "enacted": "2021-01-01", "url": "https://www.congress.gov/bill/116th-congress/house-bill/6395/text" }, "fy2024_ndaa_expansion": { "citation": "FY2024 NDAA, Section 805 (Pub. L. No. 118-31)", "enacted": "2023-12-22", "key_provision": "Establishes entity-prohibition on DoD direct contracting with Chinese Military Companies (CMCs) effective June 30, 2026, and a procurement-restriction on contractors hiring outside lobbyists for CMCs effective the same date.", "url": "https://www.congress.gov/bill/118th-congress/house-bill/2670/text" }, "current_list_update": { "citation": "DoD Section 1260H List — most recent update January 6, 2025", "url": "https://www.war.gov/News/Releases/Release/Article/4023145/dod-releases-list-of-chinese-military-companies-in-accordance-with-section-1260/", "federal_register": "Notice of Availability of Designation of Chinese Military Companies, 90 Fed. Reg., January 7, 2025", "entity_count_at_publication": 134 }, "effective_prohibition_date": "2026-06-30 (DoD contracting prohibition + procurement restriction on outside lobbyists)" }, "attestation_a_nightbox_not_on_1260h_list": { "statement": "NIGHTBOX LLC is NOT listed on the DoD Section 1260H List of Chinese Military Companies. NIGHTBOX is a Wyoming-domiciled US Limited Liability Company, registered in SAM.gov under UEI UHCAB6UXXKF2 / EIN 39-4373044, with sole-employee operations conducted in Greater Los Angeles, California, United States.", "verification_method": "Cross-checked against the current DoD 1260H List (January 6, 2025 publication) and the Federal Register Notice of Availability. NIGHTBOX LLC does not appear on the list under any name, alias, or successor designation.", "verification_date": "2026-05-16" }, "attestation_b_no_control_by_listed_entity": { "statement": "NIGHTBOX LLC is NOT controlled, directly or indirectly, by any entity on the DoD Section 1260H List. Sole-member ownership and 100% control rest with Artem Shakin, a dual US-Russian citizen, US-tax-resident, US-resident operator. No foreign government, foreign corporate entity, or foreign individual holds any ownership, control, or influence interest in NIGHTBOX LLC.", "foreign_ownership_control_influence_disclosure": "Full FOCI disclosure available at /.well-known/foci.json. The disclosure documents zero foreign-government/corporate ownership, zero foreign-control relationships, and zero relationships with any entity on US OFAC SDN, US BIS Entity List, US DoD 1260H List, EU Council restrictive-measures list, UK FCDO sanctions list, or UN Security Council sanctions list.", "verification_method": "Operator self-declaration of ownership structure, corroborated by Wyoming Secretary of State LLC records and SAM.gov entity record." }, "attestation_c_no_outside_lobbyists_for_listed_entity": { "statement": "NIGHTBOX LLC does NOT engage, retain, or pay any outside consultant, lobbyist, or representative who engages in federal lobbying activities on behalf of any entity on the DoD Section 1260H List of Chinese Military Companies.", "supplementary": "NIGHTBOX does NOT engage outside lobbyists at all — the company has no lobbying relationships of any kind. FARA (Foreign Agents Registration Act of 1938) registration is not triggered: NIGHTBOX does not represent any foreign principal. LDA (Lobbying Disclosure Act of 1995) registration is not triggered: NIGHTBOX does not engage in federal lobbying on its own behalf or on behalf of any client.", "verification_method": "Operator self-declaration; corroborated by absence of any LDA filing or FARA registration under NIGHTBOX LLC name in publicly searchable databases." }, "supply_chain_country_disclosures_per_1260h_adjacent_concerns": { "preamble": "While not strictly required by Section 1260H, NIGHTBOX provides supply-chain country disclosures here for completeness, given the adjacent concerns about PRC-origin infrastructure.", "compute_hardware_origin": ["United States (AMD)", "United States (Intel)", "Taiwan (TSMC fab dependency — standard for industry; not on 1260H List)"], "cloud_provider_origin": ["United States (Vercel)", "United States (Cloudflare)", "United States (Google Workspace)", "United States (Neon — PostgreSQL hosting)"], "banking_provider": "United States (Bank of America NA)", "section_889_compliance": "Complete — no Huawei, ZTE, Hytera, Hikvision, Dahua equipment used or sold. Documented at /.well-known/section-889.json.", "any_1260h_listed_supplier": false, "any_bis_entity_list_supplier": false, "any_ofac_sdn_relationship": false }, "attestation_statement": { "text_en": "I, Artem Shakin, Attesting Official of NIGHTBOX LLC (SAM.gov UEI UHCAB6UXXKF2), attest that: (a) NIGHTBOX LLC is not listed on the DoD Section 1260H List of Chinese Military Companies; (b) NIGHTBOX LLC is not controlled, directly or indirectly, by any entity on that list; and (c) NIGHTBOX LLC does not engage any outside consultant or lobbyist who engages in federal lobbying activities on behalf of any entity on that list. This attestation is filed in good faith in anticipation of the June 30, 2026 effective date of the DoD contracting prohibition and procurement-lobbyist restriction. I understand that false or misleading attestation may constitute a violation of the False Claims Act (31 U.S.C. §§ 3729-3733).", "method_of_signature": "Cryptographic via YubiKey FIDO2 attestation; the signed JSON-LD form of this manifest constitutes the formal attestation signature." }, "ongoing_diligence_commitment": { "preamble": "NIGHTBOX commits to ongoing diligence consistent with the FY2024 NDAA Section 805 'reasonable inquiries' standard.", "commitments": [ "NIGHTBOX will re-verify non-listing against the DoD 1260H List at least annually, and additionally upon each material change in the company's operations or upon notice of any update to the DoD list.", "NIGHTBOX will conduct reasonable inquiry before engaging any outside consultant, lobbyist, or representative to verify that the entity does not lobby on behalf of any 1260H-listed entity.", "NIGHTBOX will update this attestation upon any change that may affect any of the three core attestations." ] }, "what_this_attestation_does_NOT_cover": [ "Does NOT attest to any specific bid or solicitation — separate contract-specific attestation may be required at the time of award.", "Does NOT cover indirect supply-chain components below the documented dependency tier (e.g., individual semiconductor components within third-party hardware) — that level of indirect supply-chain attestation is beyond the practical scope of a sole-employee venture.", "Does NOT attest to BIS Entity List non-affiliation specifically, though NIGHTBOX is also not listed on the BIS Entity List (separate disclosure documented in /.well-known/foci.json).", "Does NOT cover entities not on the DoD 1260H List but otherwise restricted (e.g., OFAC SDN — separate compliance documented in /.well-known/foci.json)." ], "companion_documents": [ "https://nightboxllc.com/.well-known/sam-entity.json", "https://nightboxllc.com/.well-known/foci.json", "https://nightboxllc.com/.well-known/section-889.json", "https://nightboxllc.com/.well-known/cyber-2026-alignment.json", "https://nightboxllc.com/.well-known/cmmc-level-1-self-attestation.json" ], "contact": "artem@nightboxllc.com", "in_one_paragraph_for_anyone_summarizing_this": "NIGHTBOX LLC self-attests three core elements of Section 1260H compliance under FY2024 NDAA Section 805: (a) NIGHTBOX is not on the DoD Chinese Military Companies List (134 entities as of January 6, 2025); (b) NIGHTBOX is not controlled, directly or indirectly, by any listed entity (sole-member ownership by Artem Shakin, dual US-Russian citizen and US-resident operator — full FOCI disclosure at /.well-known/foci.json); (c) NIGHTBOX does not engage outside lobbyists who represent any listed entity (NIGHTBOX engages no outside lobbyists at all; FARA/LDA not triggered). Attestation anticipates the June 30, 2026 effective date of the DoD direct-contracting prohibition and procurement-lobbyist restriction. Supplementary supply-chain country disclosures documented (US/TW-only compute/cloud/banking; Section 889 complete). False/misleading attestation = False Claims Act exposure (31 U.S.C. §§ 3729-3733). Voluntary; CC BY 4.0." }