Foundation models are AI models, such as large-language models (LLMs), pre-trained on broad
data sets to perform different tasks. This technology can already produce realistic text, highquality
images, entertaining music, and error-free code. Regulatory frameworks like the UK’s
“Pro-Innovation Approach to AI Regulation” will be critical in ensuring the adoption of foundation
models applications in health care, education, and entertainment.
The Center would like to commend the CMA for investigating the potential impact of foundation
models but also caution that the technology and market for this technology are still in their
infancy and rapidly changing. To use an analogy, investigating market competition in AI
foundation models today would be equivalent to the CMA investigating the search engine market
in 1996when search engines like AltaVista, Excite, Lycos, and Infoseek were popular. As such,
the CMA should go slow, not act now, and adhere to the light-touch spirit of the Government’s
pro-innovation approach to AI.
Read the filing.
