Comment by Mayer Brown

According to the proposed rule, a covered US person will be required to provide quarterly reports to BIS if the US person “engages in, or plans, within six months, to engage in ‘applicable activities.’” “Applicable activities” include: “Conducting any AI model training run using more than 10^26 computational operations (e.g., integer or floating-point operations);" or acquiring, developing, or coming into possession of a computing cluster that has a set of machines transitively connected by data center networking of greater than 300 Gbit/s and having a theoretical maximum greater than 10^20 computational operations (e.g., integer or floating-point operations) per second (OP/s) for AI training, without sparsity.
Disputed source (2024)
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Disputed The source URL does contain very similar language, but the stored quote is not verbatim as presented there: on the Mayer Brown page dated September 17, 2024, the passage appears as a sentence followed by two bullet points, with the second bullet beginning "Acquiring..." and ending with a closing quotation mark; the stored version lowercases that second bullet, merges the bullets into prose, and drops the closing quote formatting. The page is also credited to five individual authors—Adam S. Hickey, Stephen Lilley, Tamer A. Soliman, Aaron Futerman, and Emily King—not to a single author named Mayer Brown, so this platform cannot verify it as a single-author quote. ([mayerbrown.com](https://www.mayerbrown.com/en/insights/publications/2024/09/us-department-of-commerce-issues-proposal-to-require-reporting-development-of-advanced-ai-models-and-computer-clusters)) · YouCongress gpt-5.4-2026-03-05 · 20h ago
Disputed The Mayer Brown source does contain substantially the same passage in a September 17, 2024 article by Adam S. Hickey, Stephen Lilley, Tamer A. Soliman, Aaron Futerman, and Emily King, published on Mayer Brown’s website. However, the submitted text is not verbatim: the source presents “Applicable activities” as two separate bullet points, with the second starting “Acquiring...” (capitalized), rather than as one continuous inline sentence as quoted here. Because the wording/formatting has been altered, I cannot confirm this as an exact verbatim quote. ([mayerbrown.com](https://www.mayerbrown.com/en/insights/publications/2024/09/us-department-of-commerce-issues-proposal-to-require-reporting-development-of-advanced-ai-models-and-computer-clusters)) · YouCongress gpt-5.4-2026-03-05 · 3d ago
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