Ari Schuler

SCHULER SECTION 207 ANALYSIS: (1) 18 USC 207(a)(1) LIFETIME BAN — HIGH RISK. If Schuler personally approved/reviewed/championed goTenna procurements while heading INVNT (his program procured goTenna mesh radios per task order naming INVNT), he is permanently barred from representing goTenna to CBP on those matters. (2) 18 USC 207(a)(2) TWO-YEAR BAN — POTENTIAL ISSUE. goTenna contracts were under his official responsibility. He left CBP ~Jan 2020, joined goTenna Mar 2021 (14 months). Two-year bar would expire ~Jan 2022. The $22.3M SBIR III was awarded Jun 2022 (2.5 years post-departure, outside window), but any pre-award engagement before Jan 2022 would be problematic. (3) 18 USC 207(c) ONE-YEAR COOLING OFF — LIKELY TECHNICALLY COMPLIANT via Daon interlude (Jan 2020-Feb 2021, 13 months). Daon is also a CBP vendor but in different product area. The interlude could be strategic parking to run out the clock. (4) NO OGE waivers, ethics opinions, or IG reports found in public record. FOIA for Schuler's OGE 278 financial disclosure would reveal recusals or conflicts.

CRITICAL REVOLVING DOOR — ARI SCHULER (Forterra/goTenna President): While serving as a DHS official, Schuler CREATED Customs and Border Protection's innovation program. He then became CEO of goTenna, which won a $99M IDIQ contract with CBP — the very program he had created. Forterra then acquired goTenna (Oct 2025), and Schuler now leads the goTenna division within Forterra. He literally built the government demand signal at DHS, walked to the supply side at goTenna, won a $99M contract from his former program, and now runs that business unit inside a $1B defense contractor. This is a textbook case of the revolving door creating the customer then serving it. Donated $2,950 to Forterra PAC.

SCHULER/CBP TIMELINE VERIFIED VIA USASPENDING: goTenna received CBP contracts WHILE Schuler ran CBP INVNT (2016-2019). Contract trail: (1) Sep 23, 2016 HSBP1016P00888 Radio Equipment $14K — 10 months after Schuler joined CBP. (2) Sep 28, 2017 HSBP1017P00747 Mesh Trackers $985K. (3) Jun 7, 2019 70B03C19P00000261 Radio Trackers $1.02M. (4) Aug 19, 2019 70B04C19P00000423 Radio Trackers $2.01M. All awarded while Schuler was Advisor to Commissioner / head of INVNT. 2024 task order 70B06C24F00000902 explicitly names 'INVNT AND AMO' as procuring office — confirming INVNT was goTenna's customer. Schuler departed CBP late 2019/Jan 2020, worked at Daon (biometrics, also CBP vendor) for 13 months, then joined goTenna as COO Mar 2021, promoted CEO Jun 2021. Post-Schuler contracts: $22.3M SBIR Phase III (Jun 2022), $99M IDIQ sole-source with ONE offer (Aug 2023). Total goTenna federal spending: $72.8M ($48.5M DHS, $23.3M DoD).

CBP INVNT-TO-GOTENNA INSTITUTIONAL CAPTURE — DOUBLE MIGRATION: Both the CREATOR (Ari Schuler) and his SUCCESSOR as INVNT Director (CHRIS PIETRZAK, 25 years at CBP) moved to goTenna. Pietrzak joined goTenna Jun 24, 2024 as VP of Solutions Architecture — goTenna press release explicitly titled 'Former Director of CBP Innovation Team Chris Pietrzak Joins goTenna.' He joined in a customer-facing role 'working with customers' on goTenna integration. The two people most responsible for CBP's commercial technology procurement program both moved to the same vendor that program procured from. goTenna's $99M CBP IDIQ (SBIR Phase III, sole-source, ONE offer) was awarded Aug 2023 — while Pietrzak was still at CBP running INVNT. He departed to goTenna 10 months later. This pattern indicates institutional capture of a government procurement program by a single vendor.