Concerns about intellectual property infringement through reverse engineering of defense spare parts are well-founded in general commercial practice. Within the specific regulatory environment governing US defense procurement and Foreign Military Sales (FMS), however, the legal framework is substantially more developed, and more permissive, than those concerns typically assume.

This white paper establishes five central points:

• Reverse engineering of defense spare parts is a federally codified acquisition method, authorized under Title 10 of the United States Code and implemented through the Federal Acquisition Regulation (FAR) and the Defense Federal Acquisition Regulation Supplement (DFARS).
• Every part on every US military platform carries a machine-readable classification code (AMC/AMSC) that defines precisely what data rights exist, who owns them, and whether reverse engineering is the authorized acquisition path. Operating within that code system is the definition of legal compliance.
• Foreign military purchasers of US platforms acquire sustainment rights through their Foreign Military Sale agreements. Saudi Arabia's $29 billion F-15SA purchase in 2010-2011, and the US State Department's February 2026 approval of an additional $3 billion F-15 sustainment package, confirm that the host nation holds legal authority to sustain its purchased platforms.
• The Air Force Security Assistance and Cooperation Directorate (AFSAC) at Wright-Patterson Air Force Base administers the Parts Repair and Ordering System (PROS-V) specifically to support FMS partners in sourcing non-standard and hard-to-support spare parts for US-origin platforms including the F-15. PROS-V is the US government's own institutional acknowledgment that FMS partners require alternative sourcing solutions.
• Congressional hearings, multiple DoD Inspector General reports, and ongoing legislative action have established that the current sole-source spare parts environment is broken, that OEM pricing power is treated as a policy problem, and that expanding competitive sourcing and reverse engineering capability is the intended policy remedy.

The primary statutory authority governing rights in technical data for defense acquisitions is Title 10 of the United States Code, Chapter 275, Subchapter I, sections 3771 through 3784. These sections were reorganized and recodified by the National Defense Authorization Act for Fiscal Year 2021 (Pub. L. 116-283), effective January 1, 2022. Prior to recodification, the governing provisions appeared at 10 USC 2320 and 2321.

Section 3771 directs the Secretary of Defense to prescribe regulations defining the legitimate interests of both the United States government and of contractors in technical data pertaining to items or processes. The statute explicitly preserves the government's authority to use data for competition and sustainment purposes, including reverse engineering, where the government has acquired appropriate rights.

Section 3772 requires that every defense contract include provisions defining respective data rights, specifying what technical data will be delivered, and establishing government remedies when contractors fail to deliver required data. The statute gives the government the right to require delivery of additional technical data for up to six years after final acceptance of contract items. This six-year window is a key mechanism for asserting rights that contractors may have attempted to limit at contract award.

Section 3771 was further amended by the FY2025 National Defense Authorization Act (signed December 23, 2024), which directed the Under Secretary of Defense for Acquisition and Sustainment to establish a formal process for identifying items suitable for reverse engineering or re-engineering. The statute specifically authorizes reverse engineering for: point-of-use manufacturing and contested logistics environments; cases where an OEM will not meet delivery schedules required for weapon system readiness; and sole-source situations where reverse engineering benefits DoD sustainment. This is the most recent and direct statutory validation of reverse engineering as a preferred policy tool.

Foreign Military Sales operate under the Arms Export Control Act (22 USC 2751 et seq.). Under this statute, the US government acts as the selling agent in FMS transactions. The host nation purchases the platform, spare parts, technical data, training, and support through a Letter of Offer and Acceptance (LOA) executed between the host government and the US government.

When a foreign nation purchases a US weapons platform through FMS, it does so with defined rights to operate and sustain that platform. The LOA specifies what technical data, documentation, training, and logistical support the purchasing nation receives. The US government, as the seller, transmits the technical data rights that it holds from its own acquisition contracts with the original equipment manufacturer.

Saudi Arabia is a Major Non-NATO Ally, a designation formally confirmed in November 2025. The kingdom's F-15 fleet, comprising approximately 210 aircraft in multiple variants, represents the second-largest F-15 operator in the world after the US Air Force. The scale of this relationship creates a compelling policy and commercial case for robust in-country sustainment capability.

FAR Part 27 (Patents, Data, and Copyrights) establishes the baseline federal acquisition framework for IP rights in government contracts. FAR Subpart 27.3 governs patent rights. FAR Subpart 27.4 addresses rights in data and copyrights. Under FAR 27.402, the government's rights in data are defined by contract, and the FAR requires that contracts include clauses specifying what data the government may use and for what purposes.

FAR Subpart 6.3 authorizes other than full and open competition when items involve unclassified but militarily sensitive technology, corresponding to AMSC S in the parts classification system. FAR Part 9 governs contractor qualifications and qualified products lists (QPL), corresponding to AMSC T. FAR 11.302 expressly allows consideration of surplus dealers and non-manufacturing sources when the parts offered were manufactured by an approved source.

DFARS Part 227 implements the Title 10 statutory requirements for defense-specific technical data rights. DFARS Subpart 227.71 governs technical data rights for other than commercial products. DFARS 252.227-7013 is the standard contract clause defining government rights in technical data and is included in virtually every defense development and production contract.

Under DFARS 227.71, technical data falls into three right tiers: unlimited rights (government may use data for any purpose, including competition); government purpose rights (government may use data for governmental purposes, which includes competitive reprocurement); and limited rights (data may be used only for reference and emergency repair). The contractor's obligation to justify limited rights assertions, and the government's right to challenge them under DFARS 252.227-7037, constrains OEM ability to declare data proprietary without substantiation.

DFARS PGI 217.75 implements the DoD Spare Parts Breakout Program — the central regulatory structure governing replenishment parts acquisition. This regulation defines the AMC/AMSC coding system, the breakout screening process, and the authorized use of reverse engineering as a last-resort acquisition method. It was revised as recently as October 30, 2023.

DFARS 217.7504 establishes a preferred hierarchy for acquiring parts when government data is unavailable: performance specifications permitting open competition first; sole-source from developer or licensees second; licensing, data rights acquisition, or leader company techniques third; and reverse engineering as the authorized last alternative.

DoD Instruction 5000.02 (Operation of the Defense Acquisition System) directs program managers to identify and address data rights early in acquisition, specifically to enable competitive reprocurement. DoD Manual 4140.1 (DoD Supply Chain Materiel Management Procedures) governs the assignment and maintenance of AMC/AMSC codes for National Stock Numbers (NSNs).

The FY2025 NDAA directed the Under Secretary of Defense for Acquisition and Sustainment to report annually to Congress through 2030 on the use of reverse engineering, disaggregated by military department. This reporting requirement signals congressional intent to actively expand, monitor, and validate reverse engineering as a systemic sustainment tool.

The Acquisition Method Code (AMC) and Acquisition Method Suffix Code (AMSC) system is the operational core of the DoD Spare Parts Breakout Program. Every centrally managed replenishment or provisioned part for military systems carries a two-character code that describes the results of a technical review and defines the legally appropriate acquisition method for that part.

The AMC is a single numeric digit (0 through 5). AMC 1 and 2 indicate competitive acquisition. AMC 3 and 4 indicate direct purchase from the actual manufacturer. AMC 5 indicates sole-source from a contractor who is not the actual manufacturer. AMC 0 indicates the part has not been screened.

Breakout screening is the formal technical and economic review that results in AMC/AMSC assignment. The full screening process involves 65 decision steps across six phases: data collection, data evaluation, data completion, technical evaluation, economic evaluation, and supply feedback.

The economic evaluation phase is directly relevant to the IP question. Reverse engineering is authorized as a last alternative when significant cost savings can be demonstrated and the head of the contracting activity authorizes it. The standard savings factor is 25 percent of projected life cycle buy value.

DFARS PGI 217.75, section 1-104(d), states that no firm shall be denied the opportunity to demonstrate its ability to furnish a part meeting the government's requirements, regardless of annual buy value or restrictive AMC/AMSC assignment. This provision is the legal basis under which alternative sourcing companies operate in the US domestic market, and under which foreign nation-supported sourcing programs can operate within their own sovereign legal frameworks.

The Air Force Security Assistance and Cooperation Directorate (AFSAC) is a directorate within the Air Force Life Cycle Management Center (AFLCMC) headquartered at Wright-Patterson Air Force Base, Ohio. AFSAC is the Air Force's principal organization for managing foreign military sales cases and providing life cycle support to FMS partner nations. AFLCMC manages all FMS cases for the Air Force and delivered the final F-15SA aircraft to Saudi Arabia under the $29 billion FMS agreement.

AFSAC supports 109 or more foreign military partner nations. Its mission explicitly includes initial equipment delivery, follow-on spare parts, repair and return services, training, technical documentation, and engineering assistance — operationalizing the FMS sustainment rights that host nations acquire through their LOAs.

The Parts Repair and Ordering System (PROS) is a major procurement contract vehicle administered by the AFSAC PROS Program Management Office at Wright-Patterson Air Force Base. PROS-V (contract FA8630-17-D-5030) was awarded to S&K Aerospace, Inc. of Warner Robins, Georgia, which uses over 400 vendors nationwide to source parts and repair services.

PROS carries an approximate value of $4.2 billion and averages over 2,000 separate supply and repair requisitions per month with a monthly value of approximately $50 million. It is tri-service capable. The F-15 has been supported under the PROS program since the 1980s.

When a nation purchases a US weapons platform through FMS, its sustainment rights are defined by the Letter of Offer and Acceptance and by the associated technical data and documentation packages transferred at the time of sale. Under US law and policy, the selling government transfers to the purchasing government those rights in technical data that the US government itself holds from its acquisition of the platform.

For the F-15, the US government has accumulated decades of technical data rights through its own acquisition and sustainment programs. Parts coded AMSC G represent technical data the government can transfer to FMS partners. Parts coded AMSC P, R, or other restricted codes represent data where OEM restrictions limit what the government can transfer. The FMS partner nation's rights track the US government's own rights.

Saudi Arabia's F-15 relationship with the United States spans four decades. The Royal Saudi Air Force inducted F-15C and F-15D fighters in the early 1980s. The 2010-2011 FMS agreement, valued at approximately $29 billion, covered 84 new-build F-15SA fighters and upgrade kits for approximately 70 F-15S aircraft. AFLCMC managed the program, with the final F-15SA delivered in 2020. The FMS agreement included spare parts, stores, simulators, training, technical documentation, base construction, and logistical and program support.

On February 3, 2026, the US State Department approved a potential additional $3.0 billion Foreign Military Sale to Saudi Arabia for F-15 sustainment. The package includes spare and repair parts, consumables, repair and return support, ground and personnel equipment, classified and unclassified software and support, publications and technical documentation, personnel training, and US government and contractor engineering, logistics, and program support.

OEM IP rights in the defense context are real but bounded by statute, regulation, and contract. Under 10 USC 3771 and DFARS Part 227, a contractor may assert limited rights in technical data developed exclusively at private expense. That assertion must be justified and documented. The government holds formal challenge procedures under DFARS 252.227-7037 to contest restrictions that lack valid support.

Under 10 USC 3771(b)(4), the government generally has the right to use technical data for operation, maintenance, installation, and training purposes even when limited rights apply to the underlying design. A part's physical dimensions, material specifications, and performance characteristics — to the extent necessary to purchase a replacement that performs the same function — are frequently available to the government even where manufacturing process details remain restricted.

DFARS PGI 217.75, Section 3-303.3(d), states directly: the existence of patent or copyright restrictions does not per se preclude securing competition. Copyright or patent markings on a technical data package are the beginning of a legal analysis, not its conclusion.

US export control law — specifically the International Traffic in Arms Regulations (ITAR, 22 CFR Parts 120-130) and the Export Administration Regulations (EAR, 15 CFR Parts 730-774) — governs the export of controlled technology and technical data to foreign persons and nations.

FMS transactions operate under the FMS exemption at 22 CFR 126.6, which authorizes the export of defense articles and technical data consistent with a formal FMS agreement. Technical data transferred to Saudi Arabia under its F-15 FMS LOAs was transferred legally under this exemption. Saudi Arabia's subsequent use of that data for sustainment of its purchased platform falls within the scope of its authorized rights.

The more nuanced question — whether analytical support and methodology assistance provided in-country constitutes export of controlled technical data or controlled know-how — is addressed in the companion white paper on corporate IP.

The most direct real-world validation of this paper's central argument comes from the United States Congress and the Department of Defense Inspector General. Beginning in 2019, a series of IG audits and congressional hearings documented systematic overpricing of sole-source defense spare parts by TransDigm Group, Inc., a private equity-style firm whose business model is to acquire companies holding sole-source contracts and then maximize pricing power through OEM IP claims.

The DoD IG's February 2019 report found excess profits on 46 of 47 parts reviewed. The December 2021 IG report found additional excess profits of at least $20.8 million on 105 of 106 spare part types examined. In some cases, excess profit margins exceeded 1,000 percent. The highest documented markup was 3,850 percent above a reasonable profit level.

TransDigm's investor communications described its pricing power as derived from "regulatory barriers that limit the number of competitors and proprietary intellectual property, which makes it a sole supplier." This framing, used to reassure investors, was cited by lawmakers as evidence that IP claims were being deployed as an anticompetitive mechanism against the public interest.

Congressional response has moved consistently toward expanding government authority to obtain cost and pricing data, increasing transparency requirements for sole-source contractors, and enabling greater use of reverse engineering and alternative sourcing. The FY2025 NDAA reverse engineering process requirement is a direct product of this legislative trajectory.

The legislative record establishes that the direction of US policy on defense spare parts IP is explicitly toward more competition, more reverse engineering, and less deference to OEM data restrictions. A methodology that helps FMS partner nations exercise their legal rights within this framework aligns with US policy intent.

Iron Horse brings to its host nation engagements an AS9100D-compatible engineering capability set built specifically for defense sustainment. This includes the full spectrum of services required to address Diminishing Manufacturing Sources and Material Shortages (DMSMS) and obsolete replacement components on military systems: reverse engineering, remanufacturing, repair, recertification, and replication.

Iron Horse's engineering approach addresses missing or incomplete technical data packages using 3D scanning, material analysis, digital modeling, and first article inspection to create manufacturable Technical Data Packages (TDPs) from parts that lack adequate original documentation. A proprietary rapid obsolescence planning and execution methodology takes a proactive approach, identifying DMSMS candidates before they create readiness gaps.

Iron Horse's reverse engineering services are oriented to recreate legacy parts, recover unavailable technical data, and support Source Approval Request (SAR) submission to the relevant military service branches. The pathway: reverse engineer the part, create a manufacturable TDP, submit a SAR, qualify as an alternate source, compete. This is precisely the breakout improvement process the DFARS prescribes and that DoD IG and Congress have called for expanding.

Iron Horse also deploys mobile laboratory capability enabling on-site reverse engineering for components that cannot leave a facility due to security, size, or sensitivity constraints. For a sovereign in-country engagement, the work stays inside the host nation at every stage.

The US domestic alternative sourcing market demonstrates that the regulatory framework supports viable commercial activity in reverse engineering and alternative parts supply. Iron Horse takes that validated capability model and structures it differently: rather than a US contractor performing this work on behalf of a foreign customer, Iron Horse builds the capability inside the host nation, owned by the host nation, operated by locally trained engineers.

The specific value this delivers — classification of parts against DFARS AMC/AMSC codes, generation of TDPs from physical analysis where documentation is unavailable, SAR development, and obsolescence management — is identical in technical content to what the US domestic market provides. The difference is structural. Iron Horse builds this as a sovereign industrial asset rather than a recurring dependency on an external contractor.

For the KSA context, Iron Horse brings US-validated technical process expertise, proven engineering methodology, in-country workforce development, and the AI-enabled data and analysis systems (SADE and SIROS) that make the capability scalable at the sovereign level. SADE provides the semi-autonomous analytical layer, with SME human-in-the-loop curation, that allows a maturing in-country team to operate at a level of analytical depth that would otherwise require decades of institutional experience to build organically.

The regulatory framework in this paper establishes a well-developed legal foundation for the Iron Horse engagement model. Several questions remain that require analysis by qualified US government contracts counsel and ITAR/EAR specialists:

• FMS case-specific terms: Individual FMS LOAs contain specific terms governing the host nation's authorized use of technical data. The specific LOA terms for Saudi Arabia's F-15 FMS cases should be reviewed to confirm scope of authorized technical data use and any restrictions on third-party involvement in sustainment activities.
• Deemed export analysis for methodology transfer: Whether Iron Horse's methodology documentation, training materials, and analytical frameworks constitute controlled technology under EAR or ITAR requires a commodity classification analysis.
• ITAR 126.6 FMS exemption scope: Whether analytical support and capacity-building services provided by US persons in-country fall within the FMS exemption or require a separate license should be confirmed for the specific service scope contemplated.
• Deemed export rules for foreign national engineers: Under EAR and ITAR, the training of foreign nationals on controlled technology constitutes a deemed export requiring a license or exemption. The specific technologies involved in F-15 parts analysis should be assessed against applicable control lists.
• KSA domestic IP law: The host nation's own IP law governs rights in work product created in-country by locally employed engineers. The relationship between KSA IP law and the US technical data rights framework should be reviewed to confirm that in-country-generated TDPs and analyses are appropriately owned and protected.

The questions above are legal confirmation questions, not fundamental viability questions. This paper establishes that: the activity contemplated is legally authorized under US law and policy; the tools to be used are explicitly provided for in federal regulation; the policy environment is actively aligned with the Iron Horse model; and the capability set Iron Horse delivers is validated by the US domestic defense market operating under the same regulatory framework.

These are not issues requiring legal analysis to resolve from first principles. They require legal review to confirm that the specific implementation structure, entity relationships, contract vehicles, and personnel arrangements are compliant with the specific regulatory requirements applicable to each element of the engagement.

The IP question that sophisticated investors appropriately raise about defense spare parts sustainment on US weapons platforms is a real question in the general commercial context. Within the specific regulatory environment governing DoD procurement and Foreign Military Sales, the United States government has already substantially answered it.

Reverse engineering is a federally codified acquisition method. Every part carries a code defining what IP rights exist and what sourcing path is authorized. The FMS structure transfers to purchasing nations the technical data rights the US government holds. AFSAC and PROS-V exist specifically to support FMS partners in sourcing parts outside standard channels. The February 2026 $3 billion Saudi F-15 sustainment approval confirms active US policy support for sustaining that fleet. Congressional record confirms that expanding competitive sourcing and reverse engineering is current and intended US policy. The US domestic defense market validates the commercial viability of this capability model.

Iron Horse's sovereign build methodology deploys human expertise and methodology in-country to build a native capability rather than exporting a product. It operates within this framework at the sovereign level. It creates IP clarity, giving a host nation the analytical tools to understand precisely what rights it holds and how to exercise them.

The remaining legal work is scoping and confirmation. That work should proceed in parallel with commercial development, grounded in the regulatory framework this paper documents.

• 10 USC 3771 — Rights in Technical Data: Regulations
• 10 USC 3772 — Rights in Technical Data: Provisions Required in Contracts
• 10 USC 3784 — Commercial Products — Presumption of Development at Private Expense
• 22 USC 2751 et seq. — Arms Export Control Act
• Pub. L. 116-283 (NDAA FY2021) — Recodification of Title 10 technical data provisions
• Pub. L. 118-159 (NDAA FY2025) — Reverse Engineering and Re-engineering Process requirements

• FAR Part 6 — Competition Requirements
• FAR Part 9 — Contractor Qualifications and Qualified Products Lists
• FAR Part 27 — Patents, Data, and Copyrights
• FAR 11.302 — Surplus Dealers and Non-Manufacturing Sources

• DFARS Part 227 — Patents, Data, and Copyrights
• DFARS Subpart 227.71 — Technical Data and Associated Rights
• DFARS 217.7504 — Acquisition of Parts When Data is Not Available
• DFARS PGI 217.75 — Acquisition of Replenishment Parts (Revised October 30, 2023)
• DFARS 252.227-7013 — Rights in Technical Data (Other Than Commercial Products)
• DFARS 252.227-7037 — Validation of Asserted Restrictions on Technical Data

• 22 CFR Parts 120-130 — International Traffic in Arms Regulations (ITAR)
• 22 CFR 126.6 — ITAR Foreign Military Sales Exemption
• 15 CFR Parts 730-774 — Export Administration Regulations (EAR)

• DoD IG Report DODIG-2019-060, "Review of Parts Purchased from TransDigm Group, Inc.," February 25, 2019
• DoD IG Report (December 2021), "Audit of the Business Model for TransDigm Group Inc."
• House Committee on Oversight and Reform Hearings on TransDigm: May 15, 2019 and January 19, 2022
• Senate correspondence, Senator Grassley to DoD, 2019-2020

• DSCA Press Release, February 3, 2026 — Kingdom of Saudi Arabia F-15 Sustainment ($3.0 billion)
• AFLCMC News Release, June 17, 2021 — "PROS is a Proven Lifeline for International Partners"
• Boeing Contract, June 18, 2025 — $49.7 million RSAF F-15 Sustainment
• Airforce-Technology.com, December 2020 — "Royal Saudi Air Force Receives Final F-15SA Fighter Aircraft"
• Defense News, "Citing TransDigm, DoD Seeks New Acquisition Powers," May 15, 2020
• Roll Call, "Lawmakers Request Review of Two Defense Industry Acquisitions," July 1, 2024