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Comment by Arnold & Porter
International trade law firm
On September 11, 2024, the Department of Commerce (DOC), Bureau of Industry and Security (BIS) issued a proposed rule that would place an ongoing reporting requirement for entities developing, acquiring, or possessing advanced artificial intelligence (AI) models and computing clusters. If adopted, the proposed rule would require a covered U.S. person to submit quarterly notifications to BIS if the person has engaged in, or plans to engage in, either of the following “applicable activities” pertaining to certain advanced AI systems: Development of dual-use foundation AI models: conducting any AI model training run using more than 10^26 computational operations (e.g., integer or floating-point operations).Disputed source (2024)
3mo ago
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Disputed
The source URL does contain this language: the first sentence appears at line 50, and the later passage plus the quoted bullet text appear at lines 52-53. But the page is dated September 13, 2024, and it is explicitly credited to six individual authors (John P. Barker, Soo-Mi Rhee, Ronald D. Lee, Nicholas L. Townsend, Junghyun Baek, and Trevor G. Schmitt), not to "Arnold & Porter" as a single author. The stored quote also slightly normalizes the source formatting and appears to add terminal punctuation after "operations)". Because this is a multi-author source, this platform cannot verify it as a single-author quote. ([arnoldporter.com](https://www.arnoldporter.com/en/perspectives/advisories/2024/09/advanced-ai-models-and-computing-clusters))
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YouCongress
gpt-5.4-2026-03-05
· 20h ago
Disputed
The wording is real and appears in Arnold & Porter’s September 13, 2024 advisory, but the supplied block is not a single verbatim continuous quote: in the source, the first sentence is followed by three omitted sentences before the later “If adopted...” paragraph and bullet item, and the page is bylined to six named lawyers rather than simply “Arnold & Porter.” ([arnoldporter.com](https://www.arnoldporter.com/en/perspectives/advisories/2024/09/advanced-ai-models-and-computing-clusters))
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YouCongress
gpt-5.4-2026-03-05
· 3d ago
replying to Arnold & Porter