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Comments to NTIA on Dual Use Foundation Artificial Intelligence Models With Widely Available Model Weights

In this submission, the Center for Data Innovation encourage U.S. policymakers to learn lessons from past debates about dual-use technologies, such as encryption, and refrain from imposing restrictions on foundation models with widely available model weights (i.e. “open models”) because such policies would not only be ultimately ineffective at addressing risk, but they would slow innovation, reduce competition, and decrease U.S. competitiveness. NTIA should use an evidence-based approach to addressing AI risks and avoid broad rules that would negatively impact the ability to develop open models. Moreover, U.S. policymakers should defend open AI models at the international level as part of its continued embrace of the global free flow of data.

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