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. Unverified source (2024)