I regularly do work for overseas clients using open source imaging libraries. Libraries that are _already_ available in those countries.
So, a company in China could hire local developers to download and use the same NN (Neural Network) libraries I would use, and it would be legal. But if they hire me, overseas, to use the same libraries, that would be regulated as a technology exchange and possibly not allowed? That HURTS commerce. In an open source world, this sort of thing is ridiculous. It limits american companies by preventing them from competing internationally with already existing technologies - image classification, for example, is a Widely discussed topic, and many of the original theories and the techniques we use came from people outside the US - but thanks to international scientific sharing and open source, we - like everyone else - get to use and benefit from these techniques.
And these technologies are everywhere - they are not militarily purposed/used. These days - Our cellphones use NN to determine what sort of 'scene' we point the camera at and adjust the exposure/brightness/contrast appropriately - whether for a selfie or a food shot. Snapchat and many apps use facial recognition that uses Neural Networks - AI image classification and recognition - to implement filters. So, you're telling me a company in China can develop a new fox-face filter for their snapchat-alike app using the same techniques and libraries we can all download, but it would be bad/wrong for an american company to make such a filter and sell it on the Chinese market? No, if such regulation were to be used, the stipulations must be much more specific than just including image classification and other broad AI techniques. _OF course_ we don't want American developers making weapons for foreign regimes - but to limit ALL uses of these technologies is asinine and bad for our tech sector as it cuts off a broad swath of the global market - a swath that _already_ has access to these techniques.
The dept of commerce document linked in the article lists the following contact information:
ADDRESSES: You may submit comments
through either of the following:
Federal eRulemaking Portal: http:///
www.regulations.gov. The identification
number for this rulemaking is BIS 2018–
0024.
Address: By mail or delivery to
Regulatory Policy Division, Bureau of
Industry and Security, U.S. Department
of Commerce, Room 2099B, 14th Street
and Pennsylvania Avenue NW,
Washington, DC 20230. Refer to RIN
0694–AH61.
FOR FURTHER INFORMATION CONTACT:
Kirsten Mortimer, Office of National
Security and Technology Transfer
Controls, Bureau of Industry and
Security, Department of Commerce.
Phone: (202) 482–0092; Fax (202) 482–
3355; Email: Kirsten.Mortimer AT
bis.doc.gov.