I appreciate the opportunity to submit public comment on the Bureau of Industry and Security (BIS)’s Framework for Artificial Intelligence Diffusion. These comments do not represent the views of any party or special interest group but are intended to assist BIS as the agency formulates artificial intelligence (AI) export control policy.

The United States is the undisputed leader in AI technology. Yet, the recent “DeepSeek moment” demonstrates American AI leadership is far from assured. Key to enduring American AI success will be AI model diffusion.

Model diffusion is not merely an outcome but can itself be treated as a “resource” critical to fueling American AI success. Exclusively through global AI model diffusion can innovators collect R&D‑critical, globe-scale usage data. Any limit represents a limit on training data. Exclusively through global diffusion can innovators ensure globe-scale revenue streams. Over the next four years, investors have pledged an unparalleled $1 trillion in new AI investments, roughly the size of 3% of the U.S. economy. Any barriers to model diffusion could cap the revenue streams needed to recoup these investments and ensure stable future R&D. The strategic and economic importance of global AI diffusion cannot be understated.