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IA filed comments on an interim final rule to amend the Export Administration Regulations (EAR) to impose a license requirement for the export and reexport of software specially designed to automate the analysis of geospatial imagery to all destinations except Canada. IA strongly supports U.S. national security objectives, but, as drafted, this interim final rule covers a range of widely available machine learning applications and imagery with no nexus to national security. IA’s comments stated that without significant modification and clarification, the interim final rule will have the seemingly unintended consequence of helping foreign innovators outpace U.S. businesses in developing machine learning applications.

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