October 22, 2018
Peerless Technologies Corporation
Attn: General Counsel’s Office
2300 National Road
Fairborn, Ohio 45324
Dear General Counsel of Peerless Technologies Corporation:
The Project On Government Oversight (POGO) is creating a Department of Defense Revolving
Door Database on its website (pogo.org), which compiles information from public resources
regarding former senior Department of Defense officials and military officers who went on to
work for government contractors, including Peerless Technologies Corporation, from 2008 to the
present. The database is an attempt to track individuals when they leave the Department of
Defense, and inclusion in the database doesn’t represent anything illegal or a violation of ethics
rules. I have enclosed the findings relevant to Peerless Technologies Corporation and am
requesting verification or refutation of the data from you.
Any response would be greatly appreciated, as the accuracy of this information is in the best
interest of all parties. When a precise start date was not publicly available POGO chose the first
day of the month the employee said they began working for Peerless Technologies Corporation.
POGO is also interested in any related ethics opinions issued for current or former Peerless
Technologies Corporation personnel in compliance with the National Defense Authorization Act
for Fiscal Year 2008, Public Law 110-181, Sec. 847 and certifications of compliance as required
by Defense Federal Acquisition Regulation Supplement (DFARS) subpart 252.203-7005; 41
U.S.C. § 2105(c). Out of fairness to Peerless Technologies Corporation, please be assured that
any response received by POGO will be posted on the website along with the data if you so
choose.
If you have any questions, I can be reached at (202) 347-1122 or msmithberger@pogo.org.
Thank you for your time and consideration.
Sincerely,
Mandy Smithberger
Director, Center for Defense Information

 Enclosure
Revolving Door Instances
1. Individual: Frances A. Duntz
Approximate Date Joined Peerless Technologies Corporation: May 1, 2009
Synopsis: Frances A. Duntz was Deputy for Acquisition, Electronic Systems Center,
Hanscom Air Force Base in Massachusetts, retiring in 2008. In that role she was the
senior civilian responsible to the commander for an organization with an annual
budget exceeding $4 billion. The next year she joined Dayton Aerospace, a defense
industry and Pentagon consulting firm, as an associate and Peerless Technologies as a
Strategy Consultant/Program Manager. Peerless Technologies is a small business
federal contractor. According to her LinkedIn profile, as Strategy Consultant/Program
Manager she managed the contract program for the Assistant Secretary of the Air
Force Acquisition "(SAF/AQ)-sponsored Acquisition App Store, developing next
generation IT approach for Acquisition professionals." Peerless Technologies went
from receiving $8 million in Department of Defense contracts in fiscal year 2008 to
$32 million in fiscal year 2012.
Documents to Include:
https://daytonaero.com/portfolio-items/fran-duntz-ses-usaf/
https://daytonaero.com/wp-content/uploads/Duntz-Fran-11-17.pdf
https://www.documentcloud.org/documents/4572096-Fran-Duntz-LinkedIn-6-618.html
https://daytonaero.com/dayton-aerospace-customers/
http://daytonaero.com/contract-vehicles/
https://www.usaspending.gov/#/search/3ef34bc90dd5e6238893114a786152b2

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