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NTIA AI Open Model Weights RFC



Hello,

The United States National Telecommunications and Information Administration (NTIA) has a Request For Comments on the topic of AI Open Model Weights [1]. The comment period closes one week from today.

Some of the questions they are wishing to answer include:

  1. How should NTIA define ‘‘open’’ or ‘‘widely available’’ when thinking about foundation models and model weights?
  2. How do the risks associated with making model weights widely available compare to the risks associated with non-public model weights?
  3. What are the benefits of foundation models with model weights that are widely available as compared to fully closed models?
  4. Are there other relevant components of open foundation models that, if simultaneously widely available, would change the risks or benefits presented by widely available model weights?
  5. What are the safety-related or broader technical issues involved in managing risks and amplifying benefits of dual-use foundation models with widely available model weights?
  6. What are the legal or business issues or effects related to open foundation models?
    1. In which ways is open-source software policy analogous (or not) to the availability of model weights? Are there lessons we can learn from the history and ecosystem of open-source software, open data, and other ‘‘open’’ initiatives for open foundation models, particularly the availability of model weights?
    1. Are there concerns about potential barriers to interoperability stemming from different incompatible ‘‘open’’ licenses, e.g., licenses with conflicting requirements, applied to AI components?
  7. What are current or potential voluntary, domestic regulatory, and international mechanisms to manage the risks and maximize the benefits of foundation models with widely available weights?
  8. In the face of continually changing technology, and given unforeseen risks and benefits, how can governments, companies, and individuals make decisions or plans today about open foundation models that will be useful in the future?

I imagine that there are individuals on this mailing list with knowledge and experience to help answer these questions in a way that is consistent with the Debian philosophy.

Sincerely,
Cory Bloor

[1]: https://www.regulations.gov/document/NTIA-2023-0009-0001


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